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VRIJE UNIVERSITEIT
Standards, soil,
science and policy
Labelling usable knowledge for soil quality standards
in the Netherlands 1971-2000
ACADEMISCH PROEFSCHRIFT
door
geboren te Schimmert
bw.souren 18-09-2006 15:47 Pagina 4
ISBN-10: 90-9021000-8
ISBN-13: 978-90-9021000-1
Table of Contents
Voorwoord 11
2 Methodological choices 25
2.1 Contextual analysis as research strategy 25
2.2 Issues of demarcation 28
2.2.1 Methodological demarcation 28
2.2.2 Empirical demarcation 31
2.3 Research methods 32
2.3.1 Document analysis 32
2.3.2 Archive search 32
2.3.3 Interviews 33
2.4 Any recommendations? 33
3 Interpretative framework 35
3.1 A literature review 38
3.1.1 From two communities to boundary work 40
3.1.2 Knowledge for policy; from instrumental to tacit and from 43
academic to socially robust
3.1.3 The locus of knowledge production 46
3.2 Putting together the interpretative framework 50
3.2.1 Regulatory practice and the labelling of usable knowledge 50
3.2.2 Regulatory practice 51
3.2.3 Legitimising the labelling of usable knowledge 53
3.2.4 Institutional context 54
3.3 Research questions 59
Bibliography 199
Appendix 205
Summary 207
Samenvatting 217
Dankwoord 227
Curriculum Vitae 231
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Voorwoord
11
Het proefschrift heeft tot onderwerp de selectie van bruikbare kennis voor bodem-
kwaliteitsnormen in Nederland tussen 1971 en 2000. Het proefschrift is ook een
tussenstadium in de ontwikkeling van een interdisciplinaire wetenschapper. Dat
blijkt tussen de regels, uit de structuur van het proefschrift, en uit de samenstelling
van de literatuurlijst.
Groen. Zonder ingewijd te zijn in het vakgebied begon ik destijds aan een ver-
kenning van de verschillende disciplinaire benaderingen die ik zou kunnen gebrui-
ken in mijn onderzoek. Ik had practische werkervaring, nationaal en internationaal,
op het snijvlak van wetenschap en beleid, maar een theoretische basis had ik niet;
die wilde ik juist komen opdoen. Niet gehinderd door historie of door de school-
vorming binnen de sociale wetenschappen doorkruiste ik in de eerste jaren van het
onderzoek de bestuurskunde, de beleidswetenschappen en het wetenschapsonder-
zoek. Op zoek naar een benadering waarmee ik in het onderzoek aan de slag wilde.
Als disciplinair opgeleid natuurwetenschapper op ontdekkingstocht in de sociale
wetenschappen, genieten! Ik had geen aanknopingspunten. Ik kende de ongeschre-
ven wetten niet, ik kende de relevante wetenschappelijke tijdschriften niet, ik kende
de namen niet van de grote mannen en vrouwen en hun theoretische en methodo-
logische uitgangspunten. Ik kocht syllabi van vakken die me relevant leken. Ik leen-
de de sociologische klassiekers in de bibliotheek. Ik heb ze toen geen van allen gele-
zen. Wat moest er worden van de ontwikkeling van mijn sociaal wetenschappelijk
perspectief?
De kentering kwam toen ik ‘The structure of scientific revolutions’ las. Thomas
Kuhn geeft daarin zijn visie op de ontwikkeling van wetenschappelijke paradigma’s
die zo belangrijk zijn voor disciplinevorming in de wetenschap. De herkenbare
beschrijving en de overtuigende stijl waarmee Kuhn zijn visie naast die van anderen
bw.souren 18-09-2006 15:47 Pagina 12
het sociaal constructivisme te paren aan de eenvoud van het meer essentialistisch en
realistisch natuurwetenschappelijk perspectief waarin ik was gesocialiseerd. Zo werd
de ontwikkeling van het interpretatief kader voor het onderzoek het vehikel voor
mijn vorming tot interdisciplinair wetenschapper.
Wat nu bekend is over interdisciplinaire vorming plaatst mijn grillige en voor
velen onnavolgbare zoektocht in een ander licht. Interdisciplinaire vorming begint
niet met het bestuderen van de klassiekers, het eindigt er mischien wel mee. Het
begint met het zoeken naar een aansluiting tussen de nieuwe discipline en de geken-
de. Niet verwonderlijk dus dat ik alleen las wat aansloot bij mijn kennis en dat een
boek als dat van Kuhn bruggen kon slaan. Dat kenmerk van interdisciplinair leren
wordt wel omschreven als ‘jumping the tussocks’. Net als wandelen in het hoogveen
vereist interdisciplinaire vorming dat er hoge en droge, veilige plekken zijn. Veel
later ben ik Kuhn opnieuw gaan lezen, om de wetenschapsfilosofische, -historische
en -sociologische betekenis te begrijpen. Toen werd Kuhn een van de klassiekers en
zo komt ook in dit proefschrift iets van de laatste fase in de vorming tot interdis-
ciplinair wetenschapper in beeld: ‘the real beginning’.
bw.souren 18-09-2006 15:47 Pagina 13
chapter 1
1.1 On standards
When asked ‘What is a standard to you?’ these are typical answers from the respon-
dents interviewed during my research:
It is a guideline issued by government to restrict activities. The process preceding the issuing, i.e.
the development process of the guideline is also part of it. What are these restrictions, and what
are the figures in the guideline? This is all part of the standard.
A standard can comprise of a broad variety of aspects. A standard gets meaning through the
(policy context) in which it is embedded. What are the implications of exceeding a standard?
resent and what this means to the development of new standards are equally impor-
tant in this research. Standards for soil quality are typically determined in an ongo-
ing interaction between stakeholders, such as science, policy, local governments, and
industry. The exact height of such standards is therefore the outcome of an interac-
tion in which different interests prevail. The interaction of these interests is decisive
14 for the outcome of the standards. Standards for soil quality distinguish between
‘polluted soil’ and ‘clean soil’, and all possible categories in between. This is impor-
Standards for soil quality
tant to note, as this distinction has different meanings and different consequences
in the economic, social and ecological realms. With every new set of standards, the
classification of soil qualities changed. Theoretically, the same pile of soil labelled
‘clean’ today may be labelled ‘polluted’ tomorrow. Standards appear as concentra-
tion levels of substances in the soil. For example: the reference value for copper
([Cu]) is 36 mg per kilogram dry soil. Apparently, soil with a copper concentration
of 35 mg per kg dry soil differs from soil containing 37 mg per kilogram dry soil.
Not so much in terms of their physical qualities, but in terms of their qualification:
above versus below the standard. The concentration level as such is not informative
about the reasons for the demarcation it produces. The meaning of a standard, i.e.,
the reason for this demarcation, is concealed behind the figure of 36 mg per kg.
Why is soil with [Cu] of 35 different from soil with [Cu] of 37? This is a relevant
question, as the implications of this demarcation are significant.
The implications and stakes associated with the demarcation produced by a
standard are significant. Researching soil quality standards immediately implies a
study into the meaning and associated stakes concealed behind the concentration
levels.
A handful of soil does not readily appear ‘clean’ or ‘polluted’, but gets such a
label on the basis of experimental research and debate about what is meant by ‘clean’
and ‘polluted’. Classification and standardisation are social processes, while they
appear to be scientific constructs, i.e., they are materialised as scientific constructs.
In other words, standards embody social constructs, while their appearance suggests
that the distinction between clean and polluted is scientifically ‘determined’.
This hybrid character makes standards an interesting subject to study. To under-
stand this hybrid character one needs to be familiar with both the physical and
social aspects of standards. Much more is concealed behind a standard than any dis-
ciplinary approach can ever unveil. This thesis represents an interdisciplinary study
that draws attention to and exposes the hybrid character of soil quality standards.
The change in soil quality standards announced by the Cabinet in June 1997
was the third revision of the standards for soil quality in the Netherlands since
1980. That year, the discovery of severely polluted soil in a newly built suburb
(Lekkerkerk) caused an enormous public outrage among the home-owners, fearing
for the values of their houses, their health and the health of their children. When a
number of barrels leaking chemical waste, such as benzene and ethyl benzene was
bw.souren 18-09-2006 15:47 Pagina 15
discovered, it was decided to treat the whole suburb, evacuating all inhabitants, and
removing the polluted soil. The inhabitants lived at an improvised campsite
(Benzenidorm) for weeks. The Dutch Queen, who had only just been inaugurated,
visited the area and further increased the media hype about Lekkerkerk (Van de
Griendt and Janssen 2004).
15
chapter 1
Figure 1.1 Treatment
of polluted soil in
Lekkerkerk, 1980
(Van den Brink et al.
1985 p. 16).
Through public arousal and media attention, soil pollution suddenly became the
prime political issue in the summer of 1980, with the Minister of Public Health and
the Environment and the Prime Minister appearing regularly on TV for further
explications of the situation and the measures taken. To a large extent, the public
arousal legitimated the drastic measures taken, but ultimately, the comparison of the
actual soil quality with the standards provided the legitimation of the drastic and
expensive measures, because the concentrations of benzene and ethyl benzene found
in the samples exceeded the then current standards. In retrospect, 25 years later the
measures taken in Lekkerkerk were evaluated by comparing the then measured con-
centrations with the latest standards (Otte and Lijzen 2004) revealing that adequate
measures had been taken at the time, according to the latest standards. The discov-
ery and cleanup of the Lekkerkerk suburb speeded up the development of the legal
framework for foil protection (Soil Protection Act (Min.VROM 1987), Interim Soil
Pollution Act (Min.VROM 1982)). However, more important to the research
described here, is that Lekkerkerk was the impetus for the development of stan-
dards. Not only to assess potentially polluted sites, but also to determine target lev-
els for treatment schemes at polluted sites. Illustrative of this is the publication of
soil quality standards in the Interim Soil Pollution Act published in 1982.
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Table 1.1 The first standards for soil quality (the ABC values) published in the Interim Soil Pollution Act (Min.
VROM 1982). This table gives ABC values for soil and sediment. The first column lists the metals. The A values
served as a reference for clean soil. The B values represented concentrations above which further research was
required to assess the toxicity of the pollution. The C values represented concentrations above which toxicity
was beyond doubt, but further research was required to identify the appropriate treatment measures.
16
A Value B Value C Value
Standards for soil quality
The publication of these soil quality standards in the above-mentioned Interim Act
illustrated the importance that was being attached to such policy instruments.
Usually, standards are not published in Acts as it is very difficult and time-consum-
ing to change formulations laid down in Acts, making policy relatively inflexible.
This is why all later soil quality standards were published in separate policy plans,
and never in Acts. In every assessment of potentially polluted sites the standards
were used as references. The impact and costs associated with assessments and treat-
ments of polluted sites are high. Standards provided the legitimation of expensive
and large-scale remediation operations. Any modifications to such standards there-
fore have an extensive effect. Such changes require years of work in terms of scien-
tific experimentation and modeling, translating scientific finds into new concentra-
tion levels of substances. In addition, as argued above, standards are social con-
structs, and revising standards for environmental quality can only be successful if
this change is related to the social context in which these standards are developed,
negotiated, set and implemented. This thesis sheds light on the work involved in
changing the standards for soil quality between 1971 and 2000.
Table1.2 lists the successive standards for soil quality published since 1982. The
ABC values were explained in the caption of Table 1.1. The reference values were
developed as operationalisations of the guiding principle of soil policy and repre-
sented clean soil, as defined in the Soil Protection Act. Compared to the A values,
the reference values also served as references. Whether or not the reference values
are stricter compared to the A values depends on the soil type. This relation is
explained in detail in Chapters 4 and 5. The reference values were developed in a
process that involved more scientific input and advice compared to the develop-
bw.souren 18-09-2006 15:47 Pagina 17
ment of the ABC values. Target values succeeded the A values (and thereby the ref-
erence values) and intervention values succeeded the C values. Target and interven-
tion values are based on scientifically derived concentration values calculated with
Species Sensitivity Distributions. The details of these scientific and policy approach-
es are given in Chapters 4 and 6. The height of the reference values and the A val-
ues for heavy metals is the same, although their meaning is different. The interven- 17
tion values are much stricter or (almost) equal compared to the C values (see Table
chapter 1
6.3 for a comparison). Soil remediation objectives (SROs) have been developed as
parts of the soil policy renewal. These SROs are function-based. That means that
different soil quality standards apply to different land uses, while the previous stan-
dards applied irrespective to land use. Therefore, a comparison of the height of
SROs and the other standards requires a more detailed understanding of these dif-
ferent standards.
Table 1.2 Succession of standards for soil quality in the Netherlands 1982-1999. The second column
provides the year of publication, the third column gives the years in which the standards were developed.
At first glance, it looks as if standards were developed nicely one after the other; new
standards following up previous ones. However, a closer look at the table reveals that
the development of the successive standards overlaps considerably; while the refer-
ence values where published in 1988 (Min.VROM 1988), the development of the
second set of standards (target and intervention values) was already ongoing (that
development can be traced back to 1985 (Kooijman 1985b)). In between the pub-
lication of standards, scientists and policymakers were involved in a complex inter-
action resulting in the selection of the scientific models to calculate the height of
the standards. While studying this interaction, it seemed that this is exactly where
the key is to the robustness and acceptance of these environmental policy instru-
ments: the close co-operation between science and policy. This is in line with sem-
inal work done by Jasanoff on standards for environmental quality in the US
(Jasanoff 1990). The complex interaction between individual scientists and policy-
makers and the variety of committees and working groups surrounding the standard
setting process provide the checks and balances and the acceptance of the agreed
standards. The role of scientists in this process takes on different forms. It will be
bw.souren 18-09-2006 15:47 Pagina 18
illustrated that a similar working practice can be found on soil quality standards in
the Netherlands. Sometimes this co-production appears as joint actions, with sci-
entists and policymakers operating side by side, whereas at other times, science and
policy are explicitly stated to be separate domains, each with its own norms. The
complexity of the interactions and the importance of these interactions to the suc-
18 cess of the standards are concealed by the list of concentration levels published in
policy documents.
Standards for soil quality
Reference Value
Figure 1.2 The reference value for copper ([Cu]) is 36 mg/kg dry soil.
From the above it seems there are two aspects concealed. First, the interaction
between science and policy is concealed. Second, the meaning and associated stakes
attached to the exact height of the standard are concealed. As pointed out already,
this thesis sheds light on this first aspect: the interaction between science and poli-
bw.souren 18-09-2006 15:47 Pagina 19
cy. Standards reflect both the scientific knowledge available or judged relevant and
the aims of soil policy.
chapter 1
process involving (amongst other parties) science and policy. Two examples of such
representations are given below. They are typical for at least three distinct reasons.
First the process is depicyted as a linear sequence of decisions and assessments.
Second, it is suggested that the development of standards takes place in isolation
from other policy, societal or scientific developments. The development of stan-
dards is depicted as a process, driven only by an internal dynamic of decisions,
assessments and documents by the successive actors in the process. Third, loops and
feedback mechanisms are lacking. Typical for such representations is that science
and policy have distinct tasks and responsibilities and are represented as different
domains. According to this representation, policymakers formulate standards, either
to operationalise policy objectives or to set policy priorities. Initially, standards are
formulated in qualitative terms, and through the production process they are trans-
lated into quantitative standards, based on scientific knowledge that is finally eval-
uated by policymakers. The first example is from about the development of target
and intervention values (Ragas and Leuven 1993). The second example is about a
report by the Health Council (1995) on the development of integrated environ-
mental quality objectives.
Such representations of standard setting practice have been questioned by dif-
ferent authors following increasing criticism on quantitative standards, and more
precisely on the assumed objectivity of quantitative standards. In science and poli-
cy studies earlier work has been done on the development of standards and on the
roles that science and policy play in this production process. Notably studies by
Jasanoff (1986, 1989, 1990), Bal and Halffman (Bal 1998; Bal and Halffman
1998; Halffman 2003), and Bowker and Star (2000, 2001) have enriched our
understanding. These studies include comparative analyses of standard setting prac-
tices in various countries (US, UK, the Netherlands) and in various policy fields
(health, toxic substances, water quality standards). These authors provide further
indication of the inadequacy of the formal representation by uncovering that con-
siderable effort is invested to connecting daily practice to this formally representa-
tion of distinct involvement by science and policy. This ‘repair work’ (Bal 1998) has
become part of daily work for scientists and policymakers involved in standard set-
ting. Albeit differences between the studies on standard setting, they all reveal the
inadequacy of the representation of standard development processes as described
above. Science and policy do not operate as distinct and well-demarcated domains.
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20
Advisory by Consultation Experts Advisory by Standards are Advisory
Council on of Council on determined in (Council on
Industry
Standards for soil quality
Environmental Environmental
Scientific Quality Quality
Objective Standard
Advisory
0 1 2 3 4 5
years
Lowest value
Advisory value
Policy considerations
Figure 1.3 Two examples of the formal representation of the procedure to derive standards. a) procedure to derive target and
intervention values. Encircled is scientific advice (Ragas and Leuven 1993). b) procedure to derive integrated environmental quality
objectives. Above the dashed line is the scientific underpinning, below the dashed line the policy process to set the standards
(Gezondheidsraad 1995).
bw.souren 18-09-2006 15:47 Pagina 21
These studies have denoted instead that there is significant interaction and co-oper-
ation involved in the production of standards. Also, boundaries are blurred, con-
tested, and demarcated continuously. Complex interactions between science and
policy have developed and have been institutionalised to facilitate or even enable
this interaction. Jasanoff contends that it is exactly the partial integration of science
and policy in procedures, discourses and interactions that explains the relative suc- 21
cess of standards as policy instruments. The outcome of that work is relevant to the
chapter 1
policy field and the standards studied in this thesis. In previous work on this it was
revealed that the formal representation of a separate domain of science and policy
is not adequate as a representation of actual practice. Organisations involved in
developing standards for soil quality cannot be assigned the label ‘science’ or ‘poli-
cy’ unambiguously (Souren 2000; Souren et al. 2000), For instance, in the advice
about the standards for zinc, the Health Council took the implementation of poli-
cy into account and did not restrict itself to the scientific knowledge available (Van
Straalen and Souren 2002). In a broader context, Van Eijndhoven and
Groenewegen convincingly showed that (scientific) experts adopt different strate-
gies during their involvement in assessments of standards for substances (Van
Eijndhoven and Groenewegen 1991). In practice, science and policy are not as dis-
tinct as sometimes suggested in formal representations. That is the starting point of
the work described in this thesis.
This thesis provides further empirical evidence about the inadequacy of the for-
mal representation of standard setting as a representation of actual practices; the
blurring of the boundaries between science and policy is obvious in the different
cases. Furthermore, this thesis contributes to a line of research in science and poli-
cy studies in which we speak of a co-production of science and policy on instru-
ments involving technical and scientific knowledge. Typical of co-production
processes is that the location of boundaries between domains – here science and pol-
icy – is subject to debate. These debates play a boundary-demarcating role, and have
been typified by Gieryn as boundary work (Gieryn 1995, 1999). Based on her
research into environmental standard setting in the US, Jasanoff states that the cre-
ation of such boundaries of scientific expertise seems crucial to the political accept-
ability of advice’ (Jasanoff 1990 p. 236). Jasanoff further states that the political suc-
cess of what she calls ‘boundary work’ increases when agencies and advisers are
involved in negotiating the location and meaning of the boundaries. The boundary
work metaphor does pertain inasmuch to boundary demarcation (and not only to
boundary blurring).
Chapter 3 reviews three bodies of literature. From the discussion in that chapter
it becomes clear that what is problematic about the metaphors of boundaries,
boundary work and co-production, is that they still bear witness to a distinction
between ‘a policy’ and ‘a science’ domain. Illustrative is the distinction between ‘reg-
ulatory policy’ and ‘regulatory science’. Such distinctions are empirically difficult to
bw.souren 18-09-2006 15:47 Pagina 22
maintain; where does regulatory policy stop and regulatory science begin? Boundary
work metaphors have stretched the boundary line to a boundary zone, but it seems
difficult to replace the labels of science and policy by meaningful new labels that do
justice to the practices at the overlap. As science and policy have moved beyond the
meet and merge stage, this thesis refers to such practices as ‘regulatory practice’ and
22 explores this practice. Characteristic of such practice is that scientists and policy-
makers involved in producing standards have increasingly developed a common
Standards for soil quality
ground that has taken them beyond the stage of meet and merge. This common
ground provides stability, meaning and significance to social behaviour. In regula-
tory practices, usable knowledge to calculate the standards is labelled in a complex
interaction between science and policy. In this thesis usable knowledge is the knowl-
edge that used to calculate the concentration levels that later become the standards.
What exactly was usable knowledge was identified in retrospect. Not until the stan-
dards were set, it could be established what body of knowledge was used. It is that
specific body of knowledge that is referred to in this thesis by ‘usable knowledge’.
As mentioned already, the concept of boundary work increased our understand-
ing of the development of standards. However, it appeared to be insufficient for
understanding how regulatory practices operate and interact within an institutional
and organisational context. This shortcoming has been identified by Gieryn (1999)
and was transformed into the challenge for this thesis. For the interpretative frame-
work, the boundary work metaphor was complemented with insights from institu-
tional theory, notably the concept of institutional context as developed by Scott
(1995, 2001). Including an institutional concept in the interpretative framework
insight is expected to increase in how regulatory practices operate and interact with-
in an institutional and organisational context.
The formal representation of the production process of standards is proposed to
be complemented by a representation reflecting actual practice (see Figure 1.4).
This figure shows that development of standards takes place in a practice at the
overlap between science and policy. As we will see throughout the thesis, boundary
debates abound in such practices. For instance in Chapter 6, we will see how
research science becomes distinguished from regulatory science during the develop-
ment of the target and intervention values (the left boundary of the overlapping area
in Figure 1.4). In the third case study, where the development of soil remediation
objectives is analysed, the boundary between regulatory policy and regulatory sci-
ence (the right boundary of the overlapping area) is demarcated.
bw.souren 18-09-2006 15:47 Pagina 23
23
Science Standard setting Policy
chapter 1
Figure 1.4 Standard setting at the overlap of science and policy.
In the first section of this chapter the successive production processes of standards
for soil quality in the Netherlands were identified as the object of this research. One
of the characteristics of these standards is that the socially constructed nature of
‘clean’ and ‘polluted’ is concealed behind the standards in the form of concentration
levels (see Section 1.2). The meaning remains invisible until standards are exceed-
ed: fauna and flora are exposed to high concentrations with the risk of suffering
from adverse effects, human health might be adversely affected, and, often at high
costs, soil is treated with an impact on economic and social activities. The approach
in this study is unfolded in Section 1.3. Standards are produced in a regulatory prac-
tice that is developing at the overlap of science and policy where extensive bound-
ary work takes place. For a better understanding of regulatory practices, the
labelling of usable knowledge for soil quality standards in these practices is studied
in more detail. The arguments used while labelling usable knowledge are expected
to be related to the institutional context within which regulatory practices develop
and exist. This provides the legitimation for labelling. The question that has guid-
ed the research described in this thesis can now be formulated as follows:
How can we understand the labelling of usable knowledge for the development of
soil quality standards in terms of boundary work between science and policy and in
terms of the relation between regulatory practice and its institutional context?
This guiding question will be further explored in Chapters 2 and 3. This results in
the formulation of five research questions at the end of that chapter. In the empir-
ical heart of the thesis, three case studies are presented (Chapters 5, 6, 7) where reg-
ulatory practice in operation is analysed. These case studies are related to Chapter
4, where the institutional context is described. The case chapters identify the argu-
ments used in labelling usable knowledge. These arguments are related to the
dimensions of the institutional context that is described in Chapter 4. Overviews of
the development of environmental policy fields usually distinguish stages or
bw.souren 18-09-2006 15:47 Pagina 24
episodes on the basis of preselected criteria (see for example (Van Tatenhove and
Leroy 2000) and this thesis will do just that as well. This research setup shows how
the arguments applied in labelling are related to the institutional context.
The question above has guided the development of an interpretative framework
and the collection and selection of empirical material. Before explaining the inter-
24 pretative framework in more detail in Chapter 3, methodological choices are
explained in Chapter 2. The research questions are formulated at the end of
Standards for soil quality
Chapter 3.
bw.souren 18-09-2006 15:47 Pagina 25
chapter 2
Methodological choices
25
Chapter 1 concluded with the guiding question of the research. Chapter 2 discuss-
es the methodological choices made during the research, i.e., how empirical mate-
rial was collected and analysed and how the case studies were selected and related to
their context.
My knowledge about the developments in policy and in ecotoxicology was based
on my MSc. in Biology and my work for the Advisory Council for Research on
Nature and the Environment (RMNO)1 as a secretary of the working group prepar-
ing a new policy-relevant research programme in ecotoxicology (Commissie
Systeemgericht Ecotoxicologisch Onderzoek RMNO 1996). This knowledge pro-
vided a provisional understanding of the labelling of usable knowledge for soil qual-
ity standards in the Netherlands. Based on such provisional understanding of the
practice of standard setting, I constructed an interpretative framework and matched
it with the case studies. With the analysis of three intensive case studies and their
context, my factual understanding of this process of labelling usable knowledge
increased, transforming my provisional understanding into firmly grounded, ‘evi-
dence-based’ understanding (see Figure 2.2 for a visualisation).
The case study methodology stood out from the start. Several methodology papers
and textbooks provide definitions of case studies. The definition formulated by
Eisenhardt points out the adequacy of case studies for my research, as it illustrates
that cases are embedded in a setting.
1 Since 2000, the Advisory council has expanded its scope and since then includes Spatial Planning.
bw.souren 18-09-2006 15:47 Pagina 26
The case study is a research strategy which focuses on understanding the dynamics present
within single settings
(Eisenhardt 1989)
Eisenhardt suggests with her definition that case studies are adequate to reveal
26 dynamics present within a setting. This setting (or context) is portrayed as relative-
ly stable, while the case study is typically a dynamic picture. The difference between
Methodological choices
‘stable’ and ‘dynamic’ is a gradual one, of course, but such difference certainly
applies to the case studies and the institutional context in which they are embed-
ded. The case studies in this thesis focus on the labelling of usable knowledge for
specific soil quality standards; a dynamic process involving a number of actors in
regulatory practice. The context for regulatory practice is the solidified practice as
it is institutionalised, written down in extensive and various policy documents and
plans, and sedimented in research programmes and organisations.
1 2 3
Figure 2.1 Episodes and case studies on a time line. 1) reference values (Chapter 5); 2) target and intervention
values (Chapter 6); 3) soil remediation objectives (Chapter 7). 1977-1988: episode 1; 1989-1994: episode 2; 1995-1999:
episode 3.
The three case studies in this thesis shed light on the labelling of usable knowledge
for the subsequent soil quality standards. The first case study is about the develop-
ment of the reference values and is embedded in a context characterised by the start
of soil policy, the development of a research infrastructure concerning soil protec-
tion and the institutionalisation of the interaction between science and policy. The
second case study concerns the development of the target and intervention values
and is embedded in a context characterised by an increasing number of participat-
ing actors and within which a reflection takes place on the course of soil policy. Also
new concepts are developed and exchanged between science and policy (for instance
and most clearly: the risk approach). The third case study is about the development
of the soil remediation objectives and is embedded in a context where new steering
concepts for policy and science are developed. Figure 2.1 shows that the case stud-
ies are positioned within a context that is subdivided into three episodes. Each case
study is treated in a separate chapter, while the context, the long-term development
of soil policy and research, is described and interpreted in another chapter (Chapter
4). This setup allows single case analysis as well as a contextual analysis, where case
studies are related to the development in the episodes. This contextual analysis is
typical for the approach in this thesis. With this approach the dynamic develop-
bw.souren 18-09-2006 15:47 Pagina 27
ments within each case study can be studied in detail and case studies can be com-
pared. In addition, such a research strategy enables to establish a connection
between case studies and context (or setting as in the definition by Eisenhardt). In
Figure 2.1 the context is subdivided into three episodes; episode 1 between 1971
and 1988, episode 2 between 1989 and 1994, and episode 3 between 1995 and
2000. This distinction of three episodes is based on an analysis of this context while 27
applying the concept of institutional context. This concept was already introduced
chapter 2
in the previous chapter and will be further discussed in Chapter 3.
The three case studies are intensive case studies as defined by Barton Cunningham.
Intensive case study principles suggest that researchers develop an understanding of real settings
and then search for a range of explanations or interpretations. They offer an environment to
search for variables to describe a theory and to conceptualise the constructs to understand it.
(Barton Cunningham 1997 p. 401)
The empirical material is drawn from the field of soil policy and involves the
labelling of usable knowledge to calculate soil quality standards. From this empiri-
cal field a set of case studies was selected and discussed with experts. Based on the
expert opinions, the final selection of the case studies was made. The following cri-
teria applied to the case study selection.
These criteria have led to a selection of three intensive case studies. Each case study
is embedded in a context or setting to which Eisenhardt refers in her definition
above. The three case studies represent the standard setting in the given time peri-
od, simply because there are no other generic standards for soil quality developed in
soil protection policy that have a generic character and that have been developed in
a close and visible interaction between science and policy. The only other case study
that might have been included was the development of the ABC values in 1982 (see
Chapter 1 and 4 for an explanation of these standards). However, informants (see
Section 2.3.3) advised against this case study, as it was unclear and undocumented
how these standards were derived. Another suggestion for case study selection was
to analyse the development of substance-specific standards, for instance to analyse
standard settings for zinc. The second criterion of the above four made clear that
the development of one substance-specific standard should not be included as repli-
cation would abound then.
bw.souren 18-09-2006 15:47 Pagina 28
The case studies each reveal a different aspect of boundary work in the labelling
of usable knowledge between science and policy. This made single case analyses pos-
sible, but also allowed cross-case comparison (third criterion). The development of
the three respective frameworks for soil quality standards was sufficiently well doc-
umented for analysis (fourth criterion). As contextual analysis was at the core of the
28 research strategy, the selection of cases studies implied the demarcation of the con-
text. That context was defined as the institutionalised development of soil policy
Methodological choices
and science and demarcated by its relevance for the development of soil quality
standards. In other words, the demarcation of the context followed from the case
study selection. To allow for contextual analysis of each of the case studies, I
searched and found demarcating events or developments in this context that were
related to the case studies.
Now, the set-up of the research consisting of case studies and episodes is com-
plete and as follows. The first episode starts in 1971 and ends in 1988. The first case
study, pertaining to labelling usable knowledge for the reference values, is embed-
ded in this episode and demarcated between 1986 and 1988. The second episode
starts in 1989 and ends in 1994. In this second episode, the second case study, per-
taining to labelling usable knowledge for target and intervention values, is studied.
This case study is demarcated between 1991 and 1994. The third episode is the
shortest; it starts in 1995 and ends in 2000. The third case study pertains to
labelling usable knowledge for soil remediation objectives and is demarcated
between 1997 and 1999. Conclusions are drawn for each separate case study. In
addition, the case studies are compared to draw attention to developments on
labelling usable knowledge throughout the period analysed in this research. The
length of the episodes and case studies differs. The cases are located towards the end
of the episode. While the episodes get shorter, the cases are comparable and all span
two to three years. The three episodes, which provide the setting for the case stud-
ies, are characterised and described in Chapter 4. The basis for demarcation of the
case studies and of the episodes is discussed in Section 2.2.
Interpretation implies that there are no self-evident, simple or unambiguous rules or procedures,
and that crucial ingredients are the researcher’s judgement, intuition, ability to ‘see and point
bw.souren 18-09-2006 15:47 Pagina 29
something out’, as well as the consideration of a more or less explicit dialogue – with the
research subject, with aspects of the researcher herself that are not entrenched behind a research
position, and with the reader.
(Alvesson and Sköldberg 2000 p.248)
As explained above, the guiding question of the thesis was based on my provision- 29
al understanding of the empirical field and theoretical concepts. With that provi-
chapter 2
sional understanding, more empirical material on the recent history of standard set-
ting for soil quality was interpreted, thereby transforming it into understanding,
and directing the further development of the theoretical perspective. In an iterative
mode, provisional understanding, through reading and pondering about possible
interpretations of the empirical material became understanding. In the same vein,
the interpretative framework gradually developed from a confrontation of theoreti-
cal perspectives with empirical material, searching for insightful interpretations of
the empirical material. Such a cycle, in which the researcher moves back and forth
between understanding and provisional understanding has been described as a
hermeneutic cycle (see (Alvesson and Sköldberg 2000) for an elaborate description
of reflexive research approaches and their relation to hermeneutic and critical
research approaches).
Provisional understanding
Understanding
Figure 2.2 The first hermeneutic cycle. After (Alvesson and Sköldberg 2000).
Besides this cyclic process, a second cyclic process is at the heart of interpretative
methodology. The second hermeneutic cycle represents the relation between the
part (case study) and the whole (context). These units of analysis are different and
in their interaction they create and increase each other’s meaning and significance.
In this thesis, as explained above, this contextual analysis stood out.
Looking at contextual analysis from a methodological perspective makes clear
that the case studies must be understood as studies in which a magnifying glass is
used to look at the ‘production’ of context. Through the labelling of usable knowl-
bw.souren 18-09-2006 15:47 Pagina 30
Context (Chapter 4)
30
Methodological choices
Case (Chapters 5, 6, 7)
Figure 2.3 The second hermeneutic cycle. After (Alvesson and Sköldberg 2000) and as described by,
e.g., Gadamer (1975) and Bernstein (1983).
.
Regulatory
practice
argument argument
Institutional
argument
context
argument
Figure 2.4 Visualisation of the relation between context (institutional context, Chapter 4) and cases (regulatory
practice, Chapters 5, 6, 7). The inner, smallest ellipse represents regulatory practice. In regulatory practice usable
knowledge is labelled. The arguments used for this labelling connect and anchor regulatory practice to the
institutional context; the outer ellipse.
bw.souren 18-09-2006 15:47 Pagina 31
chapter 2
The first date refers to the installation of the Ministry of Public Health and the
Environment and the first step in the development of a legal framework for soil pol-
icy (see Chapter 4). The end of the studied time span is determined for practical
reasons, which coincided with the publication of the results of the soil remediation
objectives shortly before (BEVER regiegroep 1999).
Second, the research was restricted to the standards developed within the frame-
work of protective soil policy; in other words, the standards developed to inform
policy about the size of the soil pollution problem, to determine the urgency and
priority for clean-up, and to direct future policy. The development of these stan-
dards was transparent and well-documented. The main reason for this demarcation
was that these standards were developed in interaction between academic science
and policy (at the national level). However, with time, the role of industry and of
other government levels increased (see for instance the analysis of the development
of standards for zinc (Van Straalen and Souren 2002) in which industry has played
a decisive role). Likewise, I chose not to focus on soil quality standards used as tar-
gets for clean-up as these standards are embedded in a setting in which a variety of
actors and interests in a public-private cooperation, thus inhibiting a focus on the
interaction between science and policy.
Third, I restricted the analysis to the development of standards. I did not look
at implementation of standards as instruments to decide about the remediation at
individual sites. Science is mostly involved in standards development and not with
that implementation. Implementation was implicitly included in the sense that
implementation problems are channelled back into the development process of sub-
sequent standards. These empirical demarcations were the consequence of my focus
on the interaction between science and policy.
Fourth, focus was on the development of the frameworks for generic standards
for soil quality, instead of zooming in on a specific substance, on a group of sub-
stances or on a specific polluted site. Although there are certainly advantages of
studying such specific standards, it would have made it much more difficult to com-
pare developments within the policy subsystem through time. In addition such
selection would imply an in-depth analysis of all actors involved in standards for
that specific substance, as well as an in-depth analysis of available (scientific) knowl-
edge on that specific substance or group of substances. In summary, the case stud-
ies were demarcated on theoretical and methodological grounds (Glaser and Strauss
bw.souren 18-09-2006 15:47 Pagina 32
1967; Huberman and Miles 2002). The final chapter provides a reflection on the
demarcations made during the research.
Relevant documents concerning the empirical material were found through litera-
ture searches, through advice and recommendations by respondents and an archive
search. Mainly, these documents were policy plans, reports by the Health Council,
the Technical Committee on Soil Protection (TCSP) and several working groups
established between 1971 and 2000 for advice on scientific and policy matters. The
more abstract and general the reports were, the more they served the analysis of the
context (Chapter 4). Especially policy plans and final reports of advisory commit-
tees were used for this purpose. More specific documents, i.e., research and confer-
ence papers, letters, memos, final reports of the Health Council and TCSP were
analysed in search of argumentation used for the labelling of usable knowledge. The
empirical chapters and Chapter 3 contain quotes from documents to illustrate how
the arguments appeared in documents.
The semi-static archives of the Ministry of Public Housing, Spatial Planning and
the Environment (VROM) in The Hague were consulted to obtain more detailed
information on the labelling processes in the respective case studies. For some
aspects of the context chapter (notably, the development of the legal framework),
the semi-static archives provided details that helped to sharpen my interpretation.
Before each visit I demarcated the subjects to study, and selected the relevant fold-
ers from the documentation from the Archives. Studying archive material of the dif-
ferent case studies revealed the different communication strategies through the
years. This posed a problem in terms of comparing the research material for the dif-
ferent case studies. In the 1970s and 1980s, people mostly corresponded through
written memos. Meanwhile, the importance of e-mail and telephone has increased.
These sources leave hardly any traces in archives. In the empirical chapters, quotes
are used from archive material to illustrate how arguments were made, but also to
revive the chapter by bringing ‘the evidence’ in.
bw.souren 18-09-2006 15:47 Pagina 33
2.3.3 Interviews
At the start of the research eight informants were interviewed2 to develop an under-
standing of the field and of the issues these informants considered interesting to
study. For the case studies and the context, 14 respondents3 were interviewed. These
respondents were affiliated to policy and science. All interviews were semi-struc- 33
tured and lasted between 1.5 to 3 hours. Respondents were selected based on their
chapter 2
role in the case study and based on suggestions from previous respondents. This
snowball method would have implied an imbalance in the number of interviews for
the respective case studies, as the number of actors involved expanded vastly. For my
final case study, the number of interviews was restricted, this was compensated by
the discussions I had had at meetings and workshops3. This difference in approach
was possible and adequate as the last case study was still ongoing during part of the
research. The first and second cases were already closed at the time.
The first group of respondents was knowledgeable on one case study. In other
words, the group consisted of case-specific respondents that had played a role in one
(or more) of the cases. The interview questions focused on that role, and on the per-
ceived interaction between science and policy. These interviews were geared towards
a reconstruction of the course of events, and involved factual questions about
events, reports, meetings, contacts. In addition, the respondent was invited to
reflect on the position of the particular case within the broader context of soil pol-
icy and standard setting. The second group of respondents consisted of generalists:
respondents that were not involved in one case in particular, but who had an
overview of the standard setting for soil quality either from a side line, or through
involvement in more than one case. With these respondents the interviews served
to check and fine-tune the interpretative framework, the context chapter and cross-
case analysis. All interviews were taped and transcribed. Quotes are used to illustrate
the appearance of arguments and the complexity of the practice of standard setting.
As explained in the first and second section, an interpretative research approach has
been adhered to. I have attempted to stay close to the empirical material, and take
a modest position concerning normative judgements about the course of events in
Chapter 4 and the arguments used for labelling in Chapters 5, 6 and 7. Such a
research approach does not combine with a normative judgement of what hap-
pened, and of how the field should proceed. This does not mean that the researcher
is invisible, nor is it suggested that the empirical material is presented without inter-
pretation. On the contrary, any researcher selects and interprets empirical material
34 at several moments during the research. That is at the heart of qualitative and espe-
cially interpretative research approaches. I have attempted to avoid to judge these
Methodological choices
events and the arguments applied in labelling. Of course, keeping track of develop-
ments and changes, and having read the critical reports, I developed a view on the
ongoing development. Although in a strict sense there may not be any impetus to
impose a normative judgement, in my view it is not befitting for two reasons. First,
an interpretative approach aims at giving the floor to the actors, positioning the
researcher at the side-line of ongoing developments in the policy field, qualified to
reflect on the course of events. Imposing a normative judgement reduces all this
careful work by putting on top of it a normative judgement by the researcher. It
assumes an out-of-place authority of the researcher. A modest position should be
taken by researchers, without regarding the views developed during the work as
irrelevant. The value of this analysis is found in the reflection on the course of
events, i.e., on the patterns emerging. Second, recommendations assume that results
from the research described here are generalisable and pertain to future develop-
ments. That is not true. Interpretative inquiries pertain to the empirical material
that is studied only (Huberman and Miles 2002). Trustworthy analyses of cases can
produce insight that can be used for future development, but any suggestion of gen-
eralisability to future developments is out of place. Therefore, recommendations
about how to proceed will not be provided. I will, however, give my opinion about
a number of issues, as issues for discussion among the actors involved in developing
standards in regulatory practices. In my view, this does justice to the actors who
have to ‘paddle their own canoe’, and to interpretative approaches.
bw.souren 18-09-2006 15:47 Pagina 35
chapter 3
Interpretative framework
35
lem of soil pollution and they play a crucial role in defining the meaning of con-
cepts like soil, clean, polluted, adverse effect, risk, etc. Related to these cognitive
concepts are the relations between involved stakeholders. These relations also play a
deciding role in defining, the meaning of these concepts. Labelling is a significant
process that largely determines the concepts used in setting quality standards.
36 This thesis is based on the assumption that the arguments applied in the labelling
process ultimately grant legitimacy to the regulatory practice. Regulatory practice is
Interpretative framework
chapter 3
parliament
Environmental Environmental
Scientific Quality Quality
Objective Standard
Advisory
0 1 2 3 4 5
years
Figure 3.1 Procedure to derive target and intervention values. Encircled is scientific advice (Ragas and Leuven 1993).
representation seems to explain the distribution of the different tasks and responsi-
bilities; it does not represent actual practice as will be shown throughout the thesis
and as was argued in Chapter 1. The scheme conceals the complex process in which
scientists and policymakers engage and reduces this complex process to a flow dia-
gram, with single pointing arrows. In practice and at the level of the individual sci-
entists (or practitioner) the demarcation between science and policy is less clear. An
excerpt from an interview with a member of a committee that assessed the scien-
tific quality of the research carried out for the production of target and interven-
tion values (second case study) illustrates this. The respondent reflects on his role
and says:
In scientific discussion you bring in policy arguments to keep the group on the track of applica-
tions, and not let the discussion get bogged down in what is scientifically at stake. Conversely, in
policy working groups, you bring in more scientific issues.
(Quote, in Van Langen (2001))
In her work on regulatory science and standard setting in the US Jasanoff (1990)
exposes boundary work by EPA (Environmental Protection Agency). In her analy-
sis she reveals that regulatory science and advisory work is as much a matter of nego-
tiation (between science and policy) as of boundary work (in the sense of clearly
demarcating the boundaries between the two). In general, the demarcation of the
38 boundaries grants political legitimacy. However, Jasanoff describes cases where legit-
imacy stemmed from the joint involvement of science and policy in explicitly nego-
Interpretative framework
tiating and determining the location and meaning of the boundaries (Jasanoff 1990
p. 236). Whether the blurring or the demarcation of the boundaries is the most suc-
cessful strategy depends on the specific type of problem under concern. This touch-
es on the relation between boundary work and the structure of problems (see, for
instance, (Turnhout 2003)).
In order to provide a context and background to the approach, a literature
review is presented in this thesis, which discusses three themes of research in science
and policy studies on boundary work. Together, these themes make it clear that
boundary work is multi-faceted; it concerns both the social and the cognitive
aspects of the relation between science and policy. The strength of the concept of
boundary work is that it gave, and still gives, the floor to the actual ‘work’ that is
being done by actors involved while negotiating (including blurring as well as
demarcating) the boundaries between formally distinct but related domains.
According to Gieryn, the author who laid the groundwork and empirical proof for
this concept, future research into boundary work should, amongst other issues, also
concern the question: In what organizational or institutional arenas does the
boundary-work occur? (Gieryn 1999 p.29). In the upcoming section literature is
brought together to explain different perspectives on boundary work, which were
used during the research. This literature has inspired the interpretation of the cases
and is used in Chapter 4 upto and including 7. In relation to the issues identified
by Gieryn as important for further research, I developed an interpretative frame-
work with related research questions in the second part of this chapter, where the
interpretative framework is explained.
The literature review in this section discusses the themes of research that have con-
tributed to the development of the interpretative framework presented in full in
Section 3.2. The different themes discuss the aspects of the relation between science
and policy that affect, and in turn are affected by, boundary work.
The first theme is discussed in Section 3.1.1 and concerns the social structure of
the science-policy relation. This section starts by discussing the ‘two communities’
metaphor that distinguished science and policy as two distinct domains. Gradually,
bw.souren 18-09-2006 15:47 Pagina 39
this focus on the difference between domains faded and was replaced by concepts
focusing on commonalities between domains. Obviously, it is the awareness of
sharedness that triggers boundary work; as long as two domains are distinct, there is
no need to engage in discussions about the exact location of boundaries. Reversely,
boundary work also ‘produces’ sharedness. This part of the literature review makes it
clear that the recognition of a shared ground, a commonality between science and 39
policy is crucial to boundary work.
chapter 3
Section 3.1.2 deals with the second theme and discusses literature about the
changed status of (scientific) knowledge. Boundary work and the status of scientif-
ic knowledge relative to other types of knowledge are related. With boundary work,
the authority of scientific knowledge over other types of knowledge as legitimate
grounds for decisions and policy has become the subject of debate. Reversely, it
could be argued that boundary work is exemplary for the decreased authority of sci-
entific knowledge. There is no cause-effect chain connecting boundary work and
the levelling out of the exclusiveness of scientific knowledge compared to other
types of knowledge (notably local and tacit knowledge).
Section 3.1.3 discusses the third theme and brings together literature about
observed or required changes in the locus of knowledge production. A crucial
notion in this literature is that the complexity of the societal problems at stake calls
for new ‘arrangements’ and new types of problem-solving strategies and knowledge
production (transdisciplinary knowledge, post-normal science). A related concept
about the knowledge infrastructure is the concept of Mode II, that is based on
(according to the authors) observed shifts in the mode of knowledge production.
From this review it appears that boundary work as a concept has many facets.
Not all of these are carved out as precisely as needed to increase the analytical
strength of the concept. The review shows what facets of the concept are best carved
out. Ultimately, the review identifies the background for Gieryn’s plea to set out on
an analysis of the organisational and institutional context.
An undercurrent in the literature reviewed in this section is the epistemological
development in science and policy studies. Undoubtedly, changes in knowledge
production as described by Gibbons and co-authors (1994) actually take place, and
can be observed. In the case studies, we will indeed see that the structure of research
programmes changed in line with the changes described by these authors. However,
the epistemological development in science and technology studies and in policy
studies interacts with these empirical observations. Science and policy studies have
come to focus on actual practice rather than on ideal type or rationalist representa-
tions of the science-policy relation and the scientific and policy domain. The ten-
dency to look at the actual work being done by scientists, policymakers and mem-
bers of regulatory practice determines to some extent the shifts described in these
literature reviews.
bw.souren 18-09-2006 15:47 Pagina 40
(Knorr-Cetina and Mulkay 1983; Latour 1987) that challenged the adequacy of the
CUDOS norms to describe scientific practice. These observations led to criticism
on the ‘two communities’ metaphor, questioning the adequacy of distinguishing the
domains as separate, and consequently questioning the adequacy of the linear
model in which knowledge was flowing from science into policy.
41
Science and policy are not as fundamentally different identities…What counts as knowledge in a
chapter 3
given research community is based on a negotiated reality in exactly the same way as the object of
politics. There is no science without interest, and no politics without analytical reflection.
(Albæk 1995 p. 96)
In this model of co-production, scientific knowledge and political order are co-produced at mul-
tiple stages in their joint evolution, from the stabilization of specialized factual findings in labo-
ratories and field studies to the national and international acceptance of causal explanations
offered by science and their use in decision-making.
(Jasanoff and Wynne 1998, p. 6)
The work by Jasanoff and Gieryn is exemplary of a body of literature that focused on
the position of science in a societal context and in relation to societal problems. In his
bw.souren 18-09-2006 15:47 Pagina 42
thesis, Halffman (2003) discussed this conceptual work further. He explained the
dualism in boundary work (demarcation one the one hand, and boundary spanning
on the other). He argued that both are existent and important. He also pointed out
the dualism in science studies about boundary work, where some authors are inclined
to discuss these issues with a ‘cage model’ in mind, whereas others discuss boundary
42 work with a ‘seamless web model in mind’. His plea is to actually look at what is being
done and to identify when and why demarcation abounds and when and why bound-
Interpretative framework
aries are spanned. In his thesis, he exposed the regulatory regimes on pesticides, dis-
charges and chemical substances in the US, the UK and the Netherlands. He argued
to take a close look at how boundaries of science and policy are institutionalised or
materialised in texts, objects and people (TOP approach). Boundary work could then
be interpreted as the work involved in producing TOP.
The boundary metaphor gave rise to the development of concepts emphasising
the merger of science and policy and the commonality of the daily work done in
these domains. The conceptual development is either deductively or inductively
accompanied by case studies, such as the work by (Bal 1998; Boogerd et al. 1997;
Broekhans 2003; Guston 2001; Huijs 2001; Turnhout 2003; Van den Boogaard
2002). Through this work, focus shifted away from the ‘two communities’
metaphor to the ‘boundary’ metaphor. The relevance of the literature discussed here
is that the relation between science and policy as described in the case studies could
be interpreted as veering away from the ‘two communities’ towards boundary work.
In the subsequent case studies, science and policy initially operated as two distinct
communities so to speak. In the first case study, an initial proposal for soil quality
standards was developed in a policy published in a Discussion Memorandum,
which was sent to the Technical Committee on Soil Protection for review. This
review was partly adopted and the reference values were published in 1988 in a pol-
icy plan. Gradually, scientists and policymakers developed closer ties, and developed
a sharedness that comes with boundary work. The sharedness that Jasanoff refers to
can be seen in the first episode, during which science and policy are developing clos-
er ties in an attempt to operationalise the guiding principle formulated in soil pol-
icy and explored by scientists in research programmes. In the second episode, the
boundary between science and policy begins to disappear, showing a boundary
between different types of science; regulatory science and research science. In the
third episode the relation between science and policy becomes further blurred. On
the one hand this has helped to develop research programmes in which policymak-
ers and scientists are participating. On the other hand the blurring of the bound-
aries has evoked a debate about the responsibility of specific tasks in regulatory prac-
tice. For a detailed description and analyses of the cases, the reader is referred to the
respective case study chapters (Chapters 5, 6, 7).
bw.souren 18-09-2006 15:47 Pagina 43
3.1.2 Knowledge for policy; from instrumental to tacit and from academic
to socially robust
When the two communities metaphor was the dominant model in science studies in
the 1980s, literature on the utilisation of knowledge was looking for a classification of
knowledge. In a review article Rich (1997) identified (in retrospect) three classes: 43
instrumental, conceptual, and strategic. Instrumental utilisation means a straightfor-
chapter 3
ward application of facts and findings. Instrumental utilisation could be ‘measured’ by
tracking primary sources in policy documents, either by looking at the list of litera-
ture or by asking policymakers what scientific sources they had used. The opera-
tionalisation of the second (conceptual) and third type (strategic) was far more diffi-
cult. According to Rich, this difficulty had its roots in the rationalist bias of the liter-
ature on the utilisation of knowledge and the focus on output, instead of on process.
Utilisation was on the good side and non-utilisation was on the wrong side. It seems
that one of the earliest attempts to take a critical look at this utilitarian perspective on
the role of knowledge in policy was a schedule by Larsen and Werner (1981). When
they distinguished two categories they granted non-utilisation of knowledge a similar
status to utilisation of knowledge. Both perspectives are different faces of the same
medal: the role of knowledge in policy processes. The question could now be asked,
what caused the difference between utilisation and non-utilisation?
Utilisation Non-utilisation
• complete implementation of information as • information has been considered by a
presented potential user but then rejected
• adaptation of information • nothing is done with information
• partial utilisation of information • implementation of information has not
• steps that have been taken towards occurred but is under consideration
implementation, although full implementation
has not occurred
Such a perspective can be recognised in the papers by Weiss, in which she explored
the enlightenment function (or conceptual utilisation) of knowledge. Knowledge as
enlightenment shapes our view on the environment in which we operate and plays a
role in identifying problems and getting them on the political, scientific or societal
agenda. Weiss developed the concept of enlightenment in a sequence of papers in the
1970s and 1980s (Weiss 1977, 1979, 1988) and it has been broadly used since then
(MacRae 1991; Rose 1977). Weiss (1991) linked the types of utilisation, identified
earlier, to types of knowledge or research. She classified research into: data, ideas, and
bw.souren 18-09-2006 15:47 Pagina 44
arguments. The concept of ‘research as data’ included the notion of instrumental util-
isation. It can be of importance in technically complex, confusing, and rapidly chang-
ing societal problems. In such cases, simple and straightforward information that clar-
ifies the issue can make a world of difference and be of crucial importance to the deci-
sion-making process. The similarities between this concept and the instrumental util-
44 isation concept are obvious. ‘Research as ideas’ has a more diffuse content and a more
diffuse access to the policy arena. It typically influences and shapes the perception of
Interpretative framework
the receivers or users of this type of knowledge. As such, this type of knowledge is less
traceable than ‘research as data’ and it can be almost invisible in final outcomes or pol-
icy plans. As a third class, Weiss introduced ‘research as arguments’. Weiss sketched a
situation where a policymaker receives a note from a researcher or policy analyst in
which research results have already been interpreted for the specific decision at hand.
The interpretation has added an advocacy position to the research findings. It saves
time for the policymaker and as such can increase the impact of knowledge in policy.
In her paper Weiss suggested that researchers should consider adopting an advocacy
position if they want their work to have a larger impact on policy. In doing so, she put
the issue of the boundary between research and policy on the agenda; to what extent
can scientists utter a political standpoint?
Zaltman en Deshpande drew a different typology: they distinguished between
knowledge that confirms a decision-maker’s belief and knowledge that challenges a
decision-maker’s belief (Zaltman and Deshpande 1980). This typology is a fine
example of how the external criteria (see previous section) were used to qualify sci-
entific knowledge. Not only scientific criteria can be used to qualify knowledge, but
the match with policymakers’ convictions can also serve as a criteria. Nowotny
worked along the same line with her work on ‘utilisation context’ dating back to
1982. Her work was cited in an article on research utilisation strategies:
…scientists stand in a complicated exchange relation to the context that receives their results.
This context is not only a network of social relations, but also a conflict arena. In this arena,
organizations, states, learned institutions, administrative agencies, private companies and fellow
scientists all make significant appearances. The arena is made and structured by social forces and
organized interests. This utilisation context determines how knowledge and concepts are to be
understood and used …
(Nilsson and Sunesson 1993 p. 25)
In a similar vein, Oh (1997) concluded in a review that the policy area in which the
information is entered determines the use and he adds that this issue has received lit-
tle attention in studies on the use of knowledge. Boogerd and co-authors (1997)
showed that knowledge developed to formulate policy at national level was inadequate
to solve local problems. In other words, whether or not knowledge is used depends on
the context (in this case, the government level), and not exclusively on the content. In
search of an adequate explanation for this phenomenon, Boogerd and co-authors
bw.souren 18-09-2006 15:47 Pagina 45
argued that during implementation nationally defined policies are reformulated to fit
regional and local problems. This redefinition may result in a problem definition ren-
dering some knowledge useless while other knowledge is missing and hindering an
adequate way of dealing with the local problem. Knowledge became contextualised in
the sense that criteria to judge the relevance of scientific knowledge for policy, in other
words, scientific criteria, were not sufficient and had to be complemented with crite- 45
ria for the usability of scientific knowledge.
chapter 3
This section deals with the determinants of the appropriateness of scientific
knowledge as usable knowledge. If it were no longer the internal CUDOS norms
identified by Merton that could be used to distinguish scientific knowledge from
tacit or lay knowledge, what were the grounds to assign more value to scientific (i.e.)
academic knowledge compared to for instance tacit knowledge (Polanyi 1962), lay
knowledge and local knowledge? The seminal work by Wynne on the Cumbrian
sheep farmers (Wynne 1992) provided a clear case in favour of a more integrated
approach. There are no reasons to grant scientific knowledge a more important or
exclusive status over tacit and lay knowledge; scientists proved to be wrong, and lay
people proved to be right, when it came to solving the problem of increased çesium
levels and the threat to sheep farmers. It is this recognition that provides the
groundwork for the development of interactive and participatory models in policy
making, but also in setting research agendas (for reviews of such models see (Van de
Kerkhof 2004), as a discussion of this literature is beyond the scope of my review).
Jasanoff and others have suggested characterising the scientific knowledge selected
for regulatory policy as regulatory science:
Regulatory science, however defined, its purpose clearly is to produce techniques, processes and
artifacts that further the task of policy development.
(Jasanoff 1990, p. 76)
Jasanoff ’s distinction between regulatory science and research science is valuable for
a differentiation between different types of scientific knowledge. In Chapter 6
boundary work takes place between these two types of science. Now that different
forms of knowledge proved valid and useful in contributing to the solution of com-
plex problems, the question has arisen as to what exactly differentiates scientific
knowledge from other forms of knowledge. With that, the exclusiveness of acade-
mia as producer of knowledge was called into question. Now that academia was no
longer considered as the exclusive producers of knowledge relevant to policy-mak-
ing, the organisation of ‘science-for-policy’ was open to changes. Focus shifted from
the production of knowledge towards context: what type of problems can we dis-
tinguish, what types of social structures are developing around these problems, and
what, if any, is the relation between those types and the knowledge used in solving
or managing those problems. Differentiations between structured, badly structured,
bw.souren 18-09-2006 15:47 Pagina 46
unstructured and ill structured problems were used to distinguish between roles of
(scientific) knowledge in solving these problems (Hisschemöller et al. 1997;
Hisschemöller and Hoppe 1996). Such differentiations lined up well with new ideas
about how to organise knowledge for policy. Notably, Funtowicz and Ravetz
(Funtowicz and Ravetz 1990, 1992) put up efforts by differentiating between nor-
46 mal and post-normal science. In a similar vein Gibbons’ and Nowotny’s work on
Mode I and II (Nowotny et al. 2001, 2003) sketched a new vista for science and
Interpretative framework
Where academia used to be the locus for the production of scientific knowledge, its
exclusiveness as the provider of knowledge for policy was increasingly questioned.
Two lines of work in science and policy studies have addressed the infrastructure of
knowledge production explicitly. Both will be discussed here. The first line of work
finds its roots in the work by Funtowicz and Ravetz on different types of risk assess-
ment. In their chapter (Funtowicz and Ravetz 1992) in the book by Krimsky and
Golding on social theories of risk (Krimsky and Golding 1992) they write:
We came to see that a full analysis of scientific problem solving in the modern world requires
awareness of both the factual and the value dimensions of problems, and of the complexities in
both.
(Funtowicz and Ravetz 1992 p. 253)
Funtowicz and Ravetz claim that the traditional sciences (normal sciences) focus on
regularity, simplicity and certainty (Funtowicz and Ravetz 2003), while the con-
temporary problems that society faces are characterised by uncertainties that are
beyond the possibilities of normal science, requiring a new class of science, labelled:
post-normal science4. These modern problems are characterised by uncertain facts,
values in dispute, high stakes and urgent decisions (Funtowicz and Ravetz 1992
p. 254). A bit further in their text the authors state:
4 Funtowicz and Ravetz refer to ‘normal science’ in the work of Kuhn. The origin of this terminology will not be
further explained because this would tempt me into a review on the sociology and philosophy of science, which
would obscure the line of the review at hand and be beyond the scope of my thesis.
bw.souren 18-09-2006 15:47 Pagina 47
…in the face of such uncertainties, they (scientists) too are amateurs. Hence there must be an
extended peer community and they will use extended facts…
(Funtowicz and Ravetz 1992 p. 254)
chapter 3
between insiders and outsiders with respect to the production of knowledge neces-
sary to solve problems and argues that the context determines the quality and not
the production process per se.
One of the implications of post-normal science is that issues of legitimacy and qual-
ity control have to be reconsidered. Elsewhere more extensive reasoning was pro-
vided about the relation between legitimacy and institutional context (Souren
2003). Where academia as the locus of knowledge production had developed its
own standards to assess the quality of scientific research, for instance, through peer
review, these quality control procedures have to be reconfigured in post-normal sci-
ence settings. Whose knowledge is valid, trustworthy and credible? This has pro-
duced further uncertainty but has most of all put pressure on scientists and other
experts to expose their professional integrity and practices. In an analysis of issues
related to uncertainty for scientists such new norms for scientific practices has been
labelled as ‘professional reflexivity’ (Van Asselt and Petersen 2003). Funtowicz and
Ravetz address the organisation of the knowledge infrastructure from a theoretical
perspective.
The second line of work that addresses institutional reforms of science was not
so much theoretically inspired, but rather empirically. Gibbons and co-authors
wrote down their perspective in 1994 (Gibbons et al. 1994). They called the new
arrangement, Mode II and contrasted it with Mode I. Mode II was characterised as
bw.souren 18-09-2006 15:47 Pagina 48
the implementation of the solutions and these are bound to touch the values and preferences of
different individuals and groups that have been seen traditionally as outside of the scientific and
technological system. They can now become active agents in the definition and solution of
problems as well as in the evaluation of performance.
(Gibbons et al. 1994)
The criteria to judge the quality of the science produced by Mode II are evaluated
by a larger group than the peer group of Mode I. The quality of Mode II science
has to be judged in line with its context of application. The work by Gibbons and
co-authors evoked discussions, but it was generally recognised that some sort of
transition in the mode of knowledge production was indeed taking place. With this
work, and the criticism it evoked, further attention was drawn to the social context
within which knowledge is produced and judged. Stressing the contextualisation of
science required a more thorough account of societal changes taking place, was a
common criticism. A slightly renewed group of authors, challenged to contextualise
the claim of an emerging new mode of knowledge production, composed a second
book: ‘Re-thinking science; knowledge and the public in an age of uncertainty’
(Nowotny et al. 2001). Without going into the details of this second book, its main
message is that science and society are indeed intertwined. This does not make sci-
ence prone to attacks on its special status, but instead increases the robustness of
knowledge, by its connection to society. This second book also poses new issues to
be analysed as it still leaves open the question what contextualisation actually is, and
what the implications are for the organisation of knowledge production.
In their work, the authors start from a different perspective compared to
Funtowicz and Ravetz. Where Funtowicz and Ravetz address inadequacies of nor-
mal science to develop strategies to solve modern problems, Gibbons and co-
authors attempt to explore changes in the mode of knowledge production (Gibbons
et al. 1994 p.1). They start from observation and construct a framework for inter-
preting their observation, while Funtowicz and Ravetz are after a ‘new design’ of sci-
entific practice. From the perspective of the organisation of the knowledge infra-
structure it is hard to understand that these two groups of authors do not refer to
each other in their basic publications. Apparently, the two groups of authors are in
different disciplinary communities.
The relation between these two approaches and boundary work will be evident.
bw.souren 18-09-2006 15:47 Pagina 49
Boundary work is affected by, and affects, the institutional and social organisation
of science in its relation to society and policy. The new mode of knowledge pro-
duction, Mode II, appears as temporary and heterogeneous consortia, suggesting
openness that is, however, not guaranteed. With the new locations of knowledge
production emerging, the ownership and diffusion or dissemination of knowledge
beyond the boundaries of the consortia have to be renegotiated, thereby introduc- 49
ing the issue of exclusiveness of produced knowledge. Through the backdoor, a new
chapter 3
demarcation issue appears; those inside and outside the consortium have unequal
access to knowledge produced within the consortium. The locus of knowledge pro-
duction is a theme in the case studies. In the first episode, the production of scien-
tific knowledge takes place in academia. In the second case-study, the two models
that are the subject of debate are produced in the same university, but with a very
different orientation towards the role of scientific knowledge in policy issues. In the
third episode, the new research programmes NOBIS and SKB are examples of shifts
in the research infrastructure as meant by Gibbons and co-authors. The criticism on
Gibbons’ and Nowotny’s work has exposed the difficulty of conceptualising the
context within which scientific knowledge is applied to solve or manage complex
societal problems. Gieryn’s plea for a better understanding of the organisational and
institutional context remains in full force.
In the following sections the interpretative framework developed during the
research is explained. What was searched for in the development of the interpreta-
tive framework was to develop a perspective complementary to the boundary work
perspective. This would have to increase understanding of the organisational and
institutional context within which labelling of usable knowledge takes place. In
search of such perspective I scanned the literature on organisational and institu-
tional theory for an approach that would allow me to describe the context of soil
policy. The concept of institutional context as proposed by Scott did just that. It
allowed trying and seeing what institutional perspectives can do to increase under-
standing of labelling processes in regulatory practices. The arguments applied in
labelling connect regulatory practice to its institutional context and grant legitima-
cy to the labelling process.
Applying this concept from institutional theory does not imply that I have
developed a full-fledged perspective on institutions. The concept of institutional
contexts is more instrumental to my research. Clearly, the stated aim of the thesis is
not to develop a fully fledged analysis of the institutional context, including the
identification of different institutions or their roles in developing standards for soil
quality. Rather the aim is to increase understanding of the labelling of usable knowl-
edge for soil quality standards. The demarcation of the context, as explained in
Chapter 2 was determined by the selection of the cases. That is to say that the per-
spective developed by Scott is instrumental to achieve that aim. There is a tension
between the perspective on labelling usable knowledge given in the literature review
bw.souren 18-09-2006 15:47 Pagina 50
limitations of the perspectives that float around, and set out to explore the possi-
bilities of applying these perspectives that are, at first sight, in sharp contrast, but
that are promising in the sense of increasing insight into the empirical material
under scrutiny.
duction and not to a labelling practice. In the three successive cases, I searched for
the scientific knowledge that was used to calculate and model the height of the stan-
dards for soil quality. As the interest in the research described here is in this labelling
process, a concept like socially robust science would be inadequate on methodolog-
ical grounds; I do not analyse different modes of production. Nor do I evaluate their
appropriateness for the production of usable knowledge. If I had taken this method- 51
ological perspective, the work by Nowotny would have been adequate.
chapter 3
Labelling usable knowledge is typically what policy and science do in regulatory
practices; they select usable knowledge to calculate the height of the concentration lev-
els that afterwards become standards for soil quality, published in policy documents
and implemented in soil policy. Usable knowledge is scientific knowledge accredited
by scientists and policymakers involved in developing standards to calculate the con-
centration levels of substances. The labelling of this knowledge is a social process in
which arguments are applied. What are the arguments scientists and policymakers use
in labelling? The literature on this issue provides a number of arguments for qualify-
ing knowledge. These include arguments concerning scientific quality or methodolo-
gy (i.e., the number of replicates, applied techniques, protocols, methodological bias-
es, qualification of personnel (Schotland and Bero 2002; Yearley 2002). A number of
studies point out that usable knowledge establishes a match between the scientific and
the policy discourse. Remember the distinction made by Larsen and Werner, dis-
cussed in the first literature review in Section 3.1.2, between knowledge that does or
does not match with policy. Scientifically sound knowledge that does not match pol-
icy principles or goals will not be labeled as usable knowledge.
It would be all too easy and perhaps tempting to simply label the middle part as
‘regulatory practice’. Regulatory practices analysed from such a perspective would
produce accounts about a new emerging domain that has to relate in some way or
another to science and policy and become institutionalised. A regulatory domain
would emerge, and all could start anew. Such perspective would focus on how reg-
52 ulatory practices are demarcated relative to the domains of science and policy. This
is the approach used in, for instance, Jasanoff ’s work and Gieryn’s work, in which
Interpretative framework
the boundary between science and policy is stretched into a boundary zone.
However, this creates mainly new boundaries that have to be demarcated and from
a methodological perspective such work does not lead to new approaches and
insights. In short, this is not the perspective pursued here. Chapter 2 explained the
methodological approach and presented the visualisation repeated here.
Regulatory
practice
argument argument
Institutional
argument
context
argument
Figure 3.4 Visualisation of the relation between context (institutional context, Chapter 4) and case studies
(regulatory practice, Chapters 5, 6, and 7). The inner and smallest ellipse represents regulatory practice. In
regulatory practice labelling of usable knowledge takes place. The arguments used for this labelling process
connect and anchor regulatory practice to the institutional context; the outer ellipse.
icy. Compared to boundary work, where science and policy are connected but dis-
tinguished by a boundary (flexible, but still present), practices go beyond the co-
production view. The concept of practice solves the problem of distinguishing the
activity to the structure that has plagued the boundary work concept (Pickering
1995; Schatzki et al. 2001). In the concept of practice, it is no longer necessary to
distinguish between scientific and policymaking activities as it is also no longer nec- 53
essary to distinguish a policymaker from a scientist. Even while applying the prac-
chapter 3
tice concept, there may still be empirical grounds to distinguish between scientific
and policymaking activities, and most likely, new demarcations within practices
would be distinguished. Exploring the labelling of usable knowledge in (develop-
ing) practices makes it possible to evaluate the arguments for labelling without hav-
ing to class them either typically under science or typically under policy.
The above section argues that regulatory practices are embedded in institutional con-
texts. The relation between the two is not as noncommittal as it might seem. In fact,
processes like the labelling of usable knowledge are legitimated through the relation
between regulatory practice and institutional context. In case the arguments for
labelling are not grounded in the institutional context within which the standards are
developed and implemented, labelling, and, consequently, regulatory practice, might
lose its credibility. Consequently, understanding regulatory practice and how it evolves
over time requires an analysis of the institutional context and of the relation between
the arguments applied in labelling and in the institutional context. A useful and wide-
ly accepted definition of legitimacy is the formulation by Suchman in 1995.
Legitimacy is a generalised perception or assumption that the actions of an entity are desirable,
proper or appropriate within some socially constructed system of norms, beliefs and definitions.
(Suchman 1995, p. 574)
Applied to the process of labelling, the socially constructed system of norms, beliefs
and definitions provides legitimacy to the labelling of usable knowledge. Legitimacy
issues have been and still are subjects of research in institutional theory. The cre-
ation of institutions and the way institutions at the same time create meaning,
change and stabilise our behaviour is the subject of institutional research. In search
of an adequate concept to complement the interpretative framework of this thesis,
institutional theory was explored strategically rather than exhaustively.
bw.souren 18-09-2006 15:47 Pagina 54
Institutions consist of cognitive, normative and regulative structures and activities that provide
stability and meaning to social behaviour.
(Scott 1995)
In the second edition of his review, Scott coupled the definition of legitimacy by
Suchman to his analysis of institutions when he wrote:
The socially constructed systems to which Suchman refers are, of course, institutional frame-
works. And… each of the dimensions provides a basis for legitimacy, albeit a different one.
(Scott 2001)
Scott argues here that the three dimensions of institutions are sources to legitimise
social behaviour (in this case: the labelling of usable knowledge). Applied to this
thesis, this translates into the claim that the dimensions of the institutional context
can provide legitimacy to the labelling of usable knowledge. Hence, for any regula-
tory practice to maintain stability and credibility the arguments for labelling of
usable knowledge should be based on any or all of the three dimensions. In the cases
studies, the arguments applied in labelling are identified and their relation to the
dimensions of the institutional context is analysed.
Scott’s distinction between the three dimensions has been used by several
authors in analyses similar to the analysis in this thesis. Troast and co-authors, for
instance, used the concept of institutional context as developed by Scott, to under-
stand the negotations over a specific Habitat Conservation Plan within the context
of nature conservation policy and forestry policy in the US (Troast et al. 2002).
Arguments used in the formulation of the Habitat Conservation Plan were analysed
and traced back to the three dimensions of the institutional context. In doing so,
the authors identified the sources of these arguments. Interestingly, Troast conclud-
ed that these arguments were decisive in the selection of the ‘best science’. The selec-
tion of the ‘best science’ was interpreted as an attempt to depoliticise the debate and
5 Scott labels them as pillars. Given the criticism that Hirsch, for instance, formulates in his lengthy review (Hirsch
1997) , but also see Scott’s response (Scott 1998), I have chosen to change ‘pillars’ into ‘dimensions’. Together, the
dimensions shape the institutional context.
bw.souren 18-09-2006 15:47 Pagina 55
chapter 3
ded in institutional contexts. In a comparative study on the US and the
Netherlands, they showed that the relation between the three dimensions could be
indicative of the outcome and success of such voluntary agreements. These two
studies (by Troast et al., 2002 and by Delmas and Terlaak 2002) and the approach
applied in this thesis have in common the analysis of a practice (negotiation, vol-
untary agreements, regulatory practice) as embedded in an institutional context and
also share the idea that the legitimation of such practice hinges on its connection to
the wider institutional environment. Table 3.2 gives the features of each dimension.
Table 3.2 Characteristic features of the dimensions of institutional context. (Adapted from Scott 2001 p. 52).
Dimension
R eg ula tiv e N orma tiv e C og niti v e
Basis of Expedience Social obligation Shared understanding
com plian c e
Scott allows a large degree of freedom for researchers to interpret the three dimen-
sions. Consequently, several authors have pointed out the relatively loose definition
of the dimensions and have criticised his approach for this reason (Delmas 2002;
Hirsch 1997; Hoffman and Ventresca 1999). Although these critical comments
seem valid, I still find his approach adequate and have found proof for this in the
studies mentioned above. In its simplicity, the concept as elaborated by Scott makes
explicit and operational that institutional contexts are multidimensional, but also
that processes such as the labelling of usable knowledge in regulatory practices must
be interpreted in a wider context. One of the issues encountered while applying
Scott’s concept in this research is that the process central to this thesis (labelling
bw.souren 18-09-2006 15:47 Pagina 56
usable knowledge) mainly concerns the cognitive dimension. The meaning of soil,
clean, polluted, risk, adverse effects, etc. (all cognitive concepts) is largely determined
by scientific knowledge and, consequently, the labelling process largely determines the
meaning of these concepts. The mere fact that this thesis focuses on a process that is
determinant of the cognitive aspects of soil quality standards might implicate that the
56 arguments for labelling are connected to the cognitive dimension of the institutional
context. If it were the selection processes for members of advisory committees that
Interpretative framework
were central to the research in this thesis, it could, in a similar vein, be hypothesised
that the arguments for this selection would be related to the normative dimension. In
my research I have not further elaborated on this issue. If I had chosen to study the
functioning of regulatory practices more widely, it would have been adequate and
interesting to compare processes that were related to the different dimensions. The
cognitive and normative dimensions stand out in the description of the context in
Chapter 4. Hence, these two dimensions will be explained in more detail and the
explanation of the regulative dimension will be limited.
Regulative dimension
The regulative dimension is characterised by Scott with the indicators: rules, laws
and sanctions (Scott 2001 p. 52). The regulative dimension in institutional context
has expedience as its basis of compliance and coercive mechanisms. The logic of the
regulative dimension is an instrumental one (March 1981) and the basis of legiti-
macy is legal sanctioning. Applied to the labelling of usable knowledge, arguments
based on references to legal frameworks would qualify as ‘regulative criteria’.
Standards for environmental quality have an important legal function as it comes
down to the issue of legal responsibility for cleanup, or for claims concerning
human health. The legal aspects of standards become crucial in cases of the use of
standards as targets for cleanup, or with standards or indicators related to human
health (see Delmas 2002). It is expected that the regulative criteria will not play a
major role in the labelling of usable knowledge for soil quality standards.
Normative dimension
The normative dimension according to Scott:
…defines goals or objectives (e.g., winning the game, making a profit) but also designates
appropriate ways to pursue them (e.g., rules specifying how the game is to be played, concep-
tions of fair business practice).
Some values and norms apply to all members, whereas others apply only to elected types of
actors or positions. The latter gives rise to roles: conceptions of appropriate goals and activities
for particular individuals or specified social positions.
(Scott 2001 p.55)
bw.souren 18-09-2006 15:47 Pagina 57
chapter 3
ateness (March 1981) and certification and accreditation as indicators. The norma-
tive dimension provides stability, a social order and facilitates communication and
actions (Bansal and Penner 2002).
The institutional context within which environmental quality standards are
developed was initially dominated by a limited number of actors, as we will see in
the first episode, described in Chapter 4. In subsequent episodes, the number of
actors increased, as well as their heterogeneity. In the sequence of the case studies,
we will see that the normative dimension becomes increasingly determinant of the
institutional context.
Cognitive dimension
The cognitive dimension6 refers to:
…shared conceptions that constitute the nature of social reality and the frames through which
meaning is made.
(Scott 2001 p. 57)
Scott draws from researchers from the neo-institutionalist tradition stressing the
importance of frames and beliefs to explain the basis of compliance. It is this cog-
nitive aspect that emphasises the importance of taken-for-granted-beliefs to which
organisations conform (Zucker 1983). The cognitive dimension is located by
Zucker (1991) at the level of the individual, whereas the normative and regulative
dimensions according to Zucker operate at the level of the field or organisation.
This assumption explains why institutional theory is more elaborate with regard to
processes governing the normative and regulative dimension than the cognitive
dimension. Whereas institutional theory stresses the role of institutions in diffusing
perceptions, it is not exactly clear to what extent, if any, disagreement or diverging
perceptions constrain or are constrained by the cognitive dimension. Put different-
ly, the sharedness of the meaning is not crucial, but rather the fact that issues are
framed cognitively is what determines the degree of cognitive institutionalisation
6 In his second edition, dated 2001, Scott uses the term cultural-cognitive. In his first edition, he uses the term:
cognitive. I am using the terminology from his first edition.
bw.souren 18-09-2006 15:47 Pagina 58
(Bansal and Penner 2002; Scott 1995) This is not to say that the cognitive dimen-
sion is considered less important; institutional theory recognises that the meaning
or interpretation of its members is central to understanding institutionalisation as a
process (DiMaggio 1991). Zucker (1983 p. 2) puts it strongly when she argues that
shared cognitions define what has meaning and what actions are possible.
58 Sharedness as a precondition for institutional coherence has dominated institution-
al theory. Bansal and Penner (2002), however, challenge this assumption. Their
Interpretative framework
work on newspaper firms shows that different interpretations can exist without
challenging the coherence of the institutional context. They also argue that the cog-
nitive dimension is most difficult to control. A high level of discord on the cogni-
tive dimension may be instrumental in later initiating regulative and normative
institutional changes. According to this work, agreement on cognitive aspects with-
in institutional contexts seems to be indicative of its stability.
Regulatory practices as discussed in the previous sections centre on issues of risk,
environmental quality and safety. Regulatory practices thus tend to have a cognitive
inclination. In this respect, they neatly fit into the analysis Scott gives about the con-
ditions giving rise to new institutional arrangements, based on the work of Suchman
(1995) and Weick (1995). The development, recognition, and naming of a recurrent
problem to which existing institutions have not yet provided a satisfactory repertoire
of response is a strong basis for new emerging institutional structures. The importance
of the development of shared meanings is also stressed by Choo (Choo 1996, 1998)
in his work on the ‘knowing organisation’ and on ‘making sense in organisations’. In
her MSc thesis, Buijk (2005) argued that the development of a shared understanding
of the concept of sustainability, through ‘making sense’, would strengthen the position
of a new regional organisation concerning sustainable water management in the
Dutch river area amongst other organisations in the region.
It is the cognitive dimension of institutional contexts that is close to the argu-
mentative and discursive tradition in policy studies and science studies. Examples
of this are to be found in (Fischer 2003; Fischer and Forester 1993; Hajer 1995).
Several of the cases analysed in this thesis will show that cognitive arguments are
used in the labelling process. An issue for further research would be whether this is
so because of the earlier mentioned cognitive inclination of regulatory practices. A
second question to be addressed is that other selective processes in regulatory prac-
tices should be scrutinised for the arguments. For instance, membership of com-
mittees concerning regulatory activities would provide interesting case material. If
the cognitive inclination of regulatory practices is most important, the arguments
used in selecting such committee members might as well be dominated by cogni-
tive arguments, or, as committees are normative structures, would they be norma-
tive arguments then? As labelling usable knowledge is largely concerned with the
cognitive concepts in regulatory practices, it is likely that cognitive arguments dom-
inate. It is presumed that the shared understanding of concepts like soil, risk,
bw.souren 18-09-2006 15:47 Pagina 59
adverse effects, pollution, soil quality and others determine the existence of a regu-
latory practice and to a certain extent provide the main criteria applied in the
labelling of usable knowledge for standards. In the final section of this chapter the
research questions are brought together.
59
3.3 Research questions
chapter 3
In this chapter the framework to interpret the empirical material is developed. The
guiding question formulated in the introductory chapter was:
How can we understand the labelling of usable knowledge for the development of
soil quality standards in terms of boundary work between science and policy and in
terms of the relation between regulatory practice and its institutional context?
In Chapter 4, a concise interpretation of the recent history of soil policy and science
is given. The three dimensions of institutional context are used in that chapter to
describe the developments and to distinguish and characterise three episodes.
bw.souren 18-09-2006 15:47 Pagina 60
Chapter 4 will thus provide the answer to the first research question. In the subse-
quent case chapters (Chapters 5, 6, 7) the second and third questions are addressed
and the labelling of usable knowledge for the subsequent sets of standards for soil
quality is analysed. In the concluding chapter (Chapter 8) the last two questions are
addressed and the respective questions and answers are put back into perspective.
60
Interpretative framework
bw.souren 18-09-2006 15:47 Pagina 61
chapter 4
In the first part of this thesis (Chapters 1, 2 and 3) the interpretative framework,
methodology, and research questions were developed. In this second part (Chapters
4, 5, 6 and 7), the empirical material is presented. The present chapter provides an
interpretation of soil policy as the context within which usable knowledge was
labelled for the successive soil quality standards. The chapter gives an overview of
the developments between 1971 and 2000.
Writing a concise history of a policy field is prone to criticism from insiders.
Inevitably, the overview in this chapter is not exhaustive. It has not been my aim to
write an all-encompassing history of the field. My aim has been to provide a care-
ful interpretation of recent history for the purpose of my study: to better under-
stand the arguments that are used in labelling usable knowledge for soil quality stan-
dards and to understand how regulatory practice and institutional context are
linked. The recent history provided here is composed for that purpose. In addition,
a second and more critical issue could be brought up, concerning the method
applied to analyse and describe the institutional context. As explained in the previ-
ous chapter, I have ‘sorted out’ the material collected during my research and have
distinguished three episodes in the recent history of the field. I sorted out all mate-
rial by using the three dimensions as distinguished by Scott. While doing so, a num-
ber of difficulties became explicit. These boil down to the relatedness of the dimen-
sions. While sorting out the empirical material it became clear that several events,
achievements and developments could be assigned to more than one dimension. It
cannot be objectively established whether a particular event, achievement or devel-
opment should have to be classified as cognitive, normative or regulative. For
instance, cognitive concepts (cognitive dimension) are developed through interac-
tion between actors (normative dimension). As it is, the cognitive and normative
bw.souren 18-09-2006 15:47 Pagina 62
dimensions are closely related. The same holds for the regulative and normative
dimension. Acts and rules (regulative dimension) are developed and maintained in
the interaction between actors (normative dimension). Because of this interrelated-
ness, the cognitive, normative and regulative dimensions cannot be distinguished
unambiguously. The rationale for the distinction made during this research was that
62 events, achievements and developments that were mentioned or used in interviews
and documents as important for the relations between different actors, were
Solidified regulatory practice
In April 1971, the Preliminary Soil Pollution Act was submitted (Min.V&S 1971).
The Act urges to prevent soil pollution mainly because of its adverse effects on water
quality and storage. When political fencing threatened to delay an integral devel-
opment of the Act, it was proposed to extract Waste and Chemical Substances from
the Preliminary Act and to develop separate Acts on these issues first. Repeatedly in
speeches to Parliament, in the Queen’s speech in 1974 and in the working plans of
the Ministries, the Soil Protection Act was announced. However, progress was still
slow. One of the causes of the delay was attributed to the specific characteristics of
soil; soil pollution is often invisible, hidden underneath. In addition, soil was per-
ceived as a resource, in the sense that it supplied services, such as providing the basis
for infrastructural works. Soil was subservient to infrastructural works and was not
perceived as an environmental compartment worth being protected for intrinsic val-
ues. A third cause of the delay, and a more political one at that, was the fact that
there already were a number of Acts that included aspects of soil protection. The
implementation of such Acts was the responsibility of several ministries, including
Economic Affairs, Agriculture and Fisheries, Public Housing and Spatial Planning,
and Infrastructure and Water. Not surprisingly, considerable political resistance
existed against the development of an overarching legal framework for soil protec-
tion as such an Act would inevitably reduce the authority of some ministries. This
was a political factor that delayed the publication of an overarching Soil Protection
Act. As an example of this resistance, the Ministry of Agriculture and Fisheries as
bw.souren 18-09-2006 15:47 Pagina 63
the strongest opponent claimed authority for the protection of agricultural soil by
referring to the Act on Manure and Fertiliser, and the Pesticide Act of the Ministry
(Min.L&V 1976). The dispute about competence between the Ministry of Public
Health and the Environment, and the Ministry of Public Housing and Spatial
Planning, centred on the authority over spatial planning issues. The line of reason-
ing of the Ministry of Public Health and the Environment – by then responsible for 63
the Preliminary Act – in countering these oppositions was that the high pressure on
chapter 4
land and the multiple interests involved required the formulation of an overarching
soil policy, protecting the quality of soil. In an attempt to resolve the dispute over
the development of an overarching or complementary Soil Protection Act, a minis-
terial committee (MICOB), chaired by the Prime Minister was installed in 1976
(MICOB 1976). After two meetings, chances of a solution to the dilemma were
perceived to be minimal. In an attempt to force a breakthrough in favour of an over-
arching act, the then Minister of Public Health and the Environment, Vorrink, send
a detailed letter to the Prime Minister (Min.V&M 1976c). Enclosed with the letter
was an extensive document with the revealing title: ‘Further underpinning of the need
to develop an overarching soil protection policy (Zeilmaker 1976). This document con-
tained an extensive overview of soil characteristics and potential threats to soil qual-
ity and a formulation of what was meant to be the guiding principle of soil protec-
tion policy. The document was an utterance of the body of knowledge developed at
the Ministry and responded to repeated calls for an overview of threats to soil qual-
ity. Also a list was provided with acts, committees, institutes and research groups
concerned with science or policy on soil quality. The Prime Minister sensed that a
solution within the MICOB was out of reach and took the issue back to the
Cabinet. In October 1976, the Cabinet decided that the Soil Protection Act would
have to be complementary instead of overarching as proposed by the Directorate
General Environmental Policy (DGMH) and the Ministry of Public Health and the
Environment. An inventory of activities that complemented existing Acts revealed
that only the ‘scattering of salt and sand on icy roads’ was not yet regulated and
would be the only issue to be regulated in the complementary cct. The Ministry of
Public Health and the Environment did not give in. Awaiting a change in favour of
the development of an overarching act, the department of Soil within the Ministry
of Public Health and the Environment meanwhile further developed knowledge on
soil and soil quality standards. Research projects were formulated, and a research
programme (Soil Protection) was launched.
What opened the window to proceed with an overarching act was the disclosure
of a polluted urban area (Lekkerkerk) in April 1980 and a number of severely pol-
luted sites shortly after (Merwedepolder, Griftpark, Volgermeerpolder). Chapter 1
pointed out the importance of this discovery for the progress of soil policy and, con-
sequently, for the development of soil quality standards. The development of soil pol-
icy gained momentum. However, the Ministry of Agriculture and Fisheries persisted
bw.souren 18-09-2006 15:47 Pagina 64
in its resistance. In a comment on a revised version of the act, its opposition was still
fierce. In a letter to the Ministry of Public Health and the Environment, the Ministry
of Agriculture and Fisheries claimed to have all necessary knowledge on soil and soil
quality, and objected to the establishment of a Technical Committee on Soil
Protection (TCSP) in the act (Min.L&V 1980). This committee was meant to advise
64 the Ministry on technical aspects of soil policy. This resistance was not effective, and
within a few months after the discovery in Lekkerkerk, the Soil Protection Act was
Solidified regulatory practice
sent to the Lower House in December 1980 (Min.V&M 1980). As priority lay with
the cleanup of the polluted sites, the necessary legal procedures for cleanup were
taken from the Soil Protection Act, and adapted as the Interim Soil Pollution Act.
This Interim Act was approved in stages between January and April 1983.
In the Interim Soil Pollution Act, a first set of standards (ABC values) for soil
quality was published (Min.VROM 1982). The ABC values were developed by the
Inspection of Health as an internal guideline in 1982 (Inspectie Milieuhygiëne
1982) to facilitate quick assessments of the quality of polluted sites with respect to
the risk to human health. As it was the only standard available at the time, these
ABC values were widely used as targets for the cleanup of sites.
The ABC values had been developed, as it were, on ‘a rainy Sunday afternoon’ by one of the
Inspectors. Nevertheless, we were in need of such a framework and we all carried a copy in our
pocket.
(Interview quote from a regional policymaker, responsible for treatment schemes at the time)
With the publication of the ABC values in the Interim Soil Pollution Act came a
scheduled evaluation of the standards. It was not until 1987 that the Soil Protection
Act was accorded as well. In this act, the principle of multifunctionality was formu-
lated as the guiding policy principle for soil policy (see Section 4.1.3 for further
explanation of the principle). Soil protection policy would have to result in soil of a
quality enabling multifunctional use. Although formulated as the aim of preventive
soil policy, the principle was soon used as the target level for cleanup. Initially the
ABC values were applied, but later on, the reference values were used as indicators
for ‘good’ soil quality. These targets for multifunctional soil quality (initially the A
values, later the reference values) were difficult to achieve. It soon turned out to be
difficult (technically) and expensive in many cases to reach the concentration levels.
To accommodate these cases, a clause was formulated in the act (Article 38), stating
that multifunctionality was the target of cleanup, unless location-specific circum-
stances were such that isolation, containment and monitoring measures (ICM meas-
ures)7 would suffice. These location-specific circumstances could be financial, tech-
nical or environmental and were so broadly formulated that many polluted cases
qualified for ICM measures. Clearly, the specification of the guiding principle of
multifunctionality in the Soil Protection Act had farreching implications. By 1987,
the Interim Soil Pollution Act and the Soil Protection Act existed next to each other.
It was not until 1994 that these two legal frameworks were integrated.
This section described the development of the legal framework for soil policy in
the early years of soil policy. The legal framework was important for the further 65
development of soil policy and standard setting. Firstly, the legal framework pro-
chapter 4
vided the ground for the development of standards. Already in the Priority
Memorandum on the Environment (Urgentienota milieuhygiëne) (Min.V&M
1972) and the Memorandum Environmental Health Standards (Nota milieuhy-
giënische normen) (Min.V&M 1976b) the development of standards was
announced. Secondly, the development of the legal framework made clear that sev-
eral ministries were involved in soil quality. I restricted my research to the Ministry
of Public Health and the Environment (that after a merger in 1982, became The
Ministry of Public Housing, Spatial Planning and the Environment). Thirdly, the
Technical Committee on Soil Protection (TCSP), was established in the Soil
Protection Act. This committee would have to provide advice about soil policy.
This illustrates the importance given in the policy field to scientific grounds for soil
policy.
In 1971, by the time the Preliminary Soil Pollution Act was submitted, the Ministry
of Public Health and the Environment was established (see for a biographical
impression of the start the memoires of the first director-general, prof. dr. Reij (De
Koning 1994). Within the Ministry, the Directorate General Environmental Policy
was responsible for environmental policy. In 1972, the Soil Sector was established
within this Directorate General next to the Sectors Water and Air. This Sector was
responsible for a variety of remaining issues that had in common that they did not
fall under the Sectors Water and Air within the Ministry. A variety of subjects rang-
ing from radiation and noise to toxic substances and soil protection fell under this
sector, the garbage can of environmental issues, so to speak. For the other environ-
mental compartments a legal framework, as well as quality standards had already
been developed. The main task of the sector was to develop a legal framework for
soil policy and to develop standards for soil quality.
Standards for environmental quality had been identified already as important
instruments in environmental policy before (Min.V&M 1972, 1974). In 1976 the
Memorandum Environmental Health Standards was published (Min.V&M
1976b), underlining this importance. This document was meant to give an
overview of environmental quality standards and to look ahead. In the introduction,
bw.souren 18-09-2006 15:47 Pagina 66
the Memorandum explains that the development of soil quality standards trails
behind; soil quality standards are not addressed, awaiting the development of the
legal framework and the results of the Soil Protection research programme (see
Section 4.1.4). The Memorandum is nevertheless of particular interest here as it
reveals the current ideas about environmental quality standards. Given the hetero-
66 geneity of ecosystems, it was believed that the natural occurrence of substances in
ecosystems serves as no-effect levels. Concentration levels measured in such ecosys-
Solidified regulatory practice
tems therefore would indicate the no-effect level. As we will see in Chapter 5, and
further, the measurement of concentrations in such areas does not only reveal nat-
ural occurrence, but includes diffuse pollution.
In various comments on this Memorandum Environmental Health Standards, it
is argued that the use of standards as policy instruments was insufficiently elaborat-
ed on. The difference between qualitative and quantitative standards had not been
explained. Also the Provisional Central Environmental Council (VCRMH) (later:
CRMH Central Council on Environmental Protection) was critical about the insuf-
ficient consideration that was given to the fact that the development of standards
was mainly a political process. That implied, according to the VCRMH that scien-
tific research was required to analyse and understand the social and economic
impacts and meaning of environmental quality standards. Such research was con-
sidered necessary to complement scientific research into effects of substances. The
VCRMH furthermore noted that the results of the scientific research would not be
available by the time that standards had to be set. The development of standards
therefore would have to built on available research (VCRMH 1977, 1980). In addi-
tion to the VCRMH, the Health Council formulated comments on the
Memorandum Environmental Health Standards (Gezondheidsraad 1978). The
Health Council was established to give advice on human health aspects of policy. Its
comments on the Memorandum focused on this aspect. As soil policy focused on
the ecological function, the advice of the Health Council is of limited relevance to
soil policy. However, the advice addresses standard setting in general and comments
on the relatively loose definition of what environmental standards are in the
Memorandum. The Health Council urges to be more precise on this in future pol-
icy plans. In the first episode, the role of the Health Council for development of soil
policy is limited. In episode 2, the role of the Health Council is much more impor-
tant. The main reason for this is that the mission of the Health Council was extend-
ed meanwhile, increasing the mandate of the Health Council on environmental
issues.
In 1979, within the Soil Sector at the Ministry, the Department of Soil Protection
existed next to the Department of Ecology and Environmental Toxicology and to the
Department of Research and Development. Initially, soil protection was a minor
issue. Soon after the discovery of landfills and waste dumps at the end of the 1970s
and early 1980s (Lekkerkerk, Volgermeer, Griftpark) soil protection became pre-
bw.souren 18-09-2006 15:47 Pagina 67
dominant on the political agenda, and additional resources were made available.
With this money, staff was hired with technical knowledge on soils. A significant
amount of the research budget was allocated to a soil research programme. By 1980,
the Department of Soil Protection consisted of an enthusiastic, dedicated, staff that
could avail of technical knowledge on soils.
67
There was a time when the Minister had to appear almost daily in parliament to discuss issues
chapter 4
pertaining to soil policy… and to provide files on specific issues. The department worked very
hard on these issues.
(Interview quote from policy staff member at the time)
By 1981, through a reorganisation, the Directorate Soil, Water, and Substances was
established. This Directorate existed until 1988. In 1982, a second reorganisation
took place resulting in a partial merger between the reorganised Ministry of Public
Health and the Environment and the Ministry of Public Housing and Spatial
Planning. Environment now became part of the new Ministry: Ministry of Public
Housing, Spatial Planning and the Environment (VROM). An important policy
document prepared by this staff was the Preliminary Soil Policy Plan (V-IMP
Bodem) (Min.VROM 1983). This policy plan was supposed to bridge the gap
between the acceptance of the Interim Soil Pollution Act (1983) and the acceptance
of the Soil Protection Act (awaited in 1985, but eventually put into effect in 1987).
The Preliminary Soil Policy Plan contained the outline of what was called ‘interim’
soil protection policy. It reflected on soil policy and research until then, but most
importantly it provided an outline of protective soil policy. It was referred to exten-
sively in documents about research programmes (Section 4.1.4) and became the ref-
erence point for soil policy since then. The plan also announced that the Advisory
Council for research on nature and the environment (RMNO) would get involved
in the subject of soil policy. This advisory council was established in 1981, to assist
the government in interpreting the relation between human activities and environ-
mental change. Within the advisory council, a platform for soil research (PSG-
Bodem) had already been established. Besides its description and reflection on soil
policy and research until then, the Preliminary Soil Policy Plan formulated what was
to become the backbone of soil policy. This backbone of soil policy was provided by
the principle of multifunctionality. This principle describes the quality of soil, and
in doing so, sets the objectives of soil protection and soil pollution. The concept is
explained in Section 4.1.3 and will re-appear throughout the thesis as it has played
a dominant role in the development of soil quality standards.
After the discovery of several polluted sites in the 1980s, policy on soil treat-
ment, the curative track of soil policy, had become increasingly complex. In 1984,
within the Directorate Soil, Water, and Substances, two separate departments were
established: one on Soil Pollution and one on Soil Protection. In the latter depart-
bw.souren 18-09-2006 15:47 Pagina 68
ment the Discussion Memorandum Soil Quality was written in 1986 (Min.VROM
1986). This Discussion Memorandum proposed a list of standards for soil quality
(Provisional reference values). This particular document initiated the development
of the reference values described in Chapter 5. Since 1986, further differentiation
of the department took place. Soil Protection was split into two departments:
68 Diffuse pollution and Local pollution. At the same time, Departments on
Substances and on Standards emerged and proliferated within the Directorate
Solidified regulatory practice
General (SDU 1978-1988). In the first episode the number of staff concerned with
soil policy increased and indicates the growing importance and position of soil pol-
icy. This growth was facilitated by the development of the guiding principle for soil
policy. This principle is explained in more detail in the following section.
It can be said that soil is polluted when its physical, chemical and biological characteristics have
been changed either through human interventions or otherwise, in such a way that soil is less
well equipped for functions it previously fulfilled.
(Min.V&S 1971)
The protection of soil quality was formulated very ambitiously; soil quality had to
be such that any use must be possible at any time and any place. Early 1976 ‘mul-
tifunctionality’ appeared for the first time in the minutes of the ministerial meeting
concerning the development of the Soil Protection Act (MICOB 1976). A few
months after this meeting, in April 1976, the report ‘Further underpinning of the
need to develop an overarching soil policy’ appeared and was sent to Parliament to
further support the development of the overarching Soil Protection Act. In this
report, already mentioned in Section 4.1.2, the fundamentals of soil protection were
formulated and it contained the following elaboration of the concept:
To maintain the capacity of soil to fulfill various functions, especially for the preservation of
humans, animals and plants, now and in the future- is at the core of soil protection and can be
referred to as striving after multifunctional soil quality.
(Zeilmaker 1976)
bw.souren 18-09-2006 15:47 Pagina 69
chapter 4
• Water supply (drinking water, agricultural, industrial and ecological use)
• Mining and energy
(Zeilmaker 1976)
User function
• Carrier function
• Food production
• Groundwater
• Mineral supply
Ecological and aesthetic function
• Support ecosystems
• Clean soil (in relation to ingestion)
• Nature and landscape
(Min.V&M 1980)
In that document, the ecological function was given priority in soil protection. It
was considered the crucial and most vulnerable to protect the soil ecosystem against
irreversible adverse effects. In the Preliminary Soil Policy Plan, the functions were
regrouped into four (Min.VROM 1983).
Alongside the general aims of environmental policy, a specific guiding principle for soil is that in
principle soil should maintain the capacity to properly serve various possible functions, so-called
multifunctionality of soil. To preserve these functions, essential characteristics of soil should be
protected.
(Min.VROM 1983)
bw.souren 18-09-2006 15:47 Pagina 70
• Carrier function
• Water storage
• Production function ( including agriculture and mining)
70 • Ecological function
(Min.VROM 1983)
Solidified regulatory practice
Already in 1972, at the onset of soil policy, we find a plea for scientific research in the
Priority Memorandum on the Environment (Urgentienota milieuhygiëne) (Min.
V&M 1972), a seminal policy document, setting out the urgent issues in environmen-
tal policy. This knowledge was required to develop environmental quality standards: 71
chapter 4
These abstract instruments should be based on scientific knowledge and the intensification of
scientific research is given high priority. This should result in an increased understanding of
‘nature, scale, and impact’ of pollution as well as the development of ‘clean technologies’. In
addition, scientific methods should be developed to evaluate what is acceptable and what not, to
be able to interpret the vast amount of qualitative and quantitative data that has been produced.
(Min.V&M 1972 p.51)
This plea for scientific knowledge was directly related to the development of policy
instruments (notably, standards). For standards to be adequate instruments it was
considered essential to increase knowledge. The required increase in knowledge was
specified as:
(1) drawing up an inventory of nature, scale, intensity and duration of pollution. In addition, (2)
stock must be taken of the biological characteristics of the environment, ecosystems and species. A
complete picture must include physical, chemical as well as biological (ecological) aspects.
(Min.V&M 1976b p.29)
With respect to knowledge underpinning standards, the following two points were
brought forward:
[Firstly].It is not always possible to answer the question whether sufficient knowledge is available
objectively. Secondly, even if it is acknowledged that there are gaps in knowledge, it can still be
desirable to develop standards.
(Min.V&M 1976b p.29)
This formulation provided the condition to proceed with deriving standards and act
pragmatic in case the scientific basis could not be provided. This is a crucial quote
as it implies that scientific knowledge could be waived for the sake of moving for-
ward the train of policy development. Scientific knowledge could contribute to the
development of standards (and therefore, the development of policy), but not halt
or delay it. This is related to the remark made by the VCRMH in its advice
(VCRMH 1977) that was mentioned in Section 4.1.2 about the fact that standards
development should be based on available scientific knowledge, awaiting the results
of the research programmes.
bw.souren 18-09-2006 15:47 Pagina 72
In the 1980s, available knowledge on soil had a strong physical, chemical and geo-
logical inclination. In the research agendas the abiotic part of soil was the focal point.
It is worthwhile to note that physical, physicochemical and chemical processes have received
much more attention in the past compared to biological processes. This might be related to the
72 higher complexity of processes within and among living systems and organisms. We regret this
gap in knowledge on these processes now that protection of the environment calls for quantita-
Solidified regulatory practice
The development of scientific knowledge on soil, and the effects of soil pollution
was organised in research programmes that were to a large extent funded by the
Ministry of Public Housing, Spatial Planning and the Environment. It is important
to keep in mind that the Ministry deliberately steered the development of scientif-
ic knowledge towards serving its policy goals. What the Ministry sought to do was
to develop a body of regulatory scientific knowledge. It did so by developing
research programmes, but also by actively establishing connections with scientists.
The establishment of the TCSP is the clearest example. The direction in which the
scientific community was being steered is shown by the following list of the pro-
grammes funded by the Ministry of Public Health and the Environment.
chapter 4
council for research on nature and the environment (RMNO) was identified as the
appropriate council to formulate the outline of such programme. In March 1985, the
(RMNO) published its analysis (commissioned by the Ministry of Education and
Research) in a report entitled Grounds for Concern (RMNO 1985). That report first
and foremost provided an overview of the results and achievements of soil research
until then. That overview was considered the prelude to a chapter in which the out-
line of a large research programme was given, with an agenda of eleven research
themes. The principle of multifunctionality provided the conceptual background for
the programme. The first theme considered the collection of basic knowledge about
the soil system: background values of substances, a typology of soil, the functioning
of soil life. The second theme concerned knowledge about the effects of pollution.
The third theme concerned treatment techniques and effects. The fourth up to and
including the tenth theme concentrated on waste production and specific effects of
specific waste. Finally, the eleventh theme was ‘research on administrative issues’. The
‘Grounds for Concern’ report provided the justification for the large programme
Netherlands Integrated Soil Research Programme (SPBO) that started in 1986. The
‘Grounds for Concern’ report used the concept of multifunctionality to identify addi-
tional issues for research: natural recovery of soil and the self-cleaning potential of soil
as well as the translation from soil processes and soil characteristics to multifunction-
ality (Min.O&W et al. 1986 p.19). The development of this knowledge was consid-
ered important to the development of soil quality standards. These standards in turn
were considered important to the operationalisation of soil policy as formulated in the
Preliminary Soil Policy Plan and in the Soil Protection Act.
At the same time, another programming report was published by a committee of
scientists established by the National Council for Agricultural Research (NRLO)
together with the Foundation for Biological Research (BION) sketching the outlines
of a research programme (Soil Biology) (NRLO 1984). The committee consisted of
scientists that were mainly associated with agricultural research. In the programme
document, the development of the research programme was legitimated by reference
to the budget of the Ministry of Education and Science, and the Ministry of
Agriculture and Fisheries. The programme document also referred to the Preliminary
Soil Policy plan (mentioned in Section 4.1.2) where the need to develop a body of
knowledge concerning the ecological function of soil was explicitly formulated.
Interesting about this programme is that it was supported by the Ministry of
bw.souren 18-09-2006 15:47 Pagina 74
Interdepartmental steering
group Policy advisory group
Anchoring committee
(1991-1992) Integration committee
(1989-1991)
Programme 75
committee
chapter 4
PCBB and PCTB
Programme
office
Figure 4.1.1 Organisational structure of SPBO. After (RMNO 1993; SPBO 1993).
this first episode, runs through the second episode, and culminates in the demarca-
tion of regulatory and research science in the case study on the development of tar-
get and intervention values.
In Figure 4.1.1, the organisational structure of the programme is given. It is a
complex structure that reflects the complexity of the double ambition of the pro-
gramme. In the steering group, four ministries were represented and at some stage
a policy advisory group was established to council the policy elaboration. This
group consisted of one representative per Ministry. Two programme committees
were established: the PCBB (Programme Committee Basic Knowledge Soil
Research) and the PCTB (Programme Committee Technology Development Soil
Research). Both committees consisted of scientists. The PCBB guided the develop-
ment of the basic knowledge (roughly themes A and C), whereas the second pro-
gramme committee PCTB, mainly guided the development of techniques for treat-
ment and prevention. Both committees were actively involved in the peer review of
research proposals. In addition, an anchoring committee was established to ensure
and strengthen the relation between research and soil policy and to prepare a pro-
posal for the continuation of a new research programme as a follow-up of the
SPBO. This committee consisted of members of both programme committees, the
programme office and two scientists outside the organisation of the programme.
The programme was prolonged until 1994 and evaluated in 1993 by the RMNO
(1993) and by the KNAW (Dutch Royal Academy of Science and Arts) (KNAW
1993). These evaluations are discussed in episode 2.
bw.souren 18-09-2006 15:47 Pagina 76
In this first episode, while getting soil policy off the ground and increasing research
efforts, the Department Soil at the Ministry considered it crucial to create
Compared to other environmental compartments of water and air and related pol-
icy fields, (such as agriculture) the development of quality standards was lagging
behind with regard to the soil compartment. In addition, research infrastructure
(i.e., institutes) already existed for the other environmental compartments, air and
water, facilitating scientific knowledge to underpin policy. The Ministry of
Infrastructure and Waterworks had its institutes (RIZA, RID, RIKZ). The Ministry
of Agriculture and Fisheries had built up a scientific network at the Wageningen
Agricultural School8 and the National Agricultural Research Institutes. For the rel-
atively new policy issue of soil protection and pollution, scientists had to be cut
loose from their ties to the Ministry of Agriculture and Fisheries. As was explained
in Section 4.1.1, the Ministry of Agriculture and Fisheries claimed to have the tech-
nical knowledge on soil and soil quality in a letter to the Ministry of Public Health
and the Environment.
In this first episode the relation between science and policy intensified. The devel-
opment of multifunctionality and the importance given to the developments of stan-
dards indicating good soil quality played a decisive role. These standards had to be
based on scientific knowledge. That knowledge was lacking at the time, and large
research programmes were being developed. The research funds in the Research
Programme Soil Protection, later continued as the Netherlands Integrated Soil
Research Programme SPBO (see Section 4.1.4), facilitated this, as did the establish-
ment of the TCSP. The committee became effective in a preliminary setup in 1985.
This committee played an important role in the labelling of usable knowledge for the
reference values, as we will see in Chapter 5. The committee consists of scientists and
experts on soil quality who advise the ministry on technical aspects of soil policy.
The above account of what qualifies as ‘getting started’ provides the institutional
context within which the labelling of usable knowledge in the first case study was
performed. Between 1971 and 1988, soil policy gained a certain position within
environmental policy. In 1971, the Ministry of Public Health and the Environment
was established. In the same year a draft act on soil pollution was send to the Lower
House. In the following year, 1972, the Soil Sector was established within the
Ministry. In 1974, a working group was installed to further the Soil Protection Act.
In this first episode, soil policy established a position relative to other environmen-
tal policies and relative to different flanking policy fields, notably agriculture, in 77
which soil quality has long since played a role. This process of acquiring a policy
chapter 4
position was prominent and successful. The acceptance of the Soil Protection Act
in 1987 was a landmark for soil protection policy. Underlying the success of soil
policy was the principle of multifunctionality. This principle was anchored in the
Soil Protection Act.
Great efforts were made to establish contacts between science and policy to
underpin the further development of soil policy. The establishment of research pro-
grammes, funded by different Ministries and the establishment of the TCSP are
illustrations of this.
As explained in Chapter 3, the institutional context could be interpreted as con-
sisting of three dimensions. In the first section of this chapter, it was explained that
events, achievements and developments could be ‘assigned’ to different dimensions.
What follows from the explanation there is that the Soil Protection Act and the
Interim Soil Pollution Act are at the regulative dimension of the institutional con-
text in this episode. These two legal frameworks provided clarity about responsibil-
ities for soil quality. They also made clear which activities were prohibited as they
endangered the multifunctional quality of soil. A focus on the normative dimension
reveals the continuous dispute of competence between the ministries over the devel-
opment of this act. Besides this competence issue between the ministries, also the
relations between the different sectors within the Ministry of Public Housing,
Spatial Planning and the Environment, representing the different environmental
compartments, played a role. An added element was that a tighter relation between
science and policy had been created by establishing the TCSP. The research pro-
grammes developed in this first episode further contributed to the closer interaction
between science and policy.
On the cognitive dimension, the principle of multifunctionality stands out.
Attempts to operationalise it had produced somewhat different typologies of func-
tions. However, the exact typology was not that relevant, as the ecological function
was already selected as most vulnerable. This selection paved the way for ecological
research programmes and for ecological soil quality standards. In Chapter 5 a first
attempt to develop such standards is studied.
It can be argued that in this episode the foundation was laid for regulatory prac-
tice. Scientists and policymakers were in close contact; staff members at the newly
established department were (besides lawyers) scientists with a background in soil
science, geology or ecology. What played an important role was the shared belief
bw.souren 18-09-2006 15:47 Pagina 78
that standards were important instruments for the development and implementa-
tion of soil policy, together with the belief that these standards had to be based on
scientific knowledge.
Table 4.1.1 summarises the institutional context in this first episode. As Chapter
3 explains, these three dimensions are expected to determine what arguments are
78 used to label usable knowledge for the development of standards developed in this
episode; the reference values. This labelling of usable knowledge is the subject of the
Solidified regulatory practice
Table 4.1.1 The three dimensions of the institutional context in the first episode. For each dimension critical
events, achievements and developments explained in the text above are given in the table.
Section 4.1 described the first episode. In 1989 a new episode started with the intro-
duction of the risk approach and new scientific concepts to underpin soil policy.
With that, the number and heterogeneity of actors involved also increased. In the
previous episode soil policy was established and connections between science and
policy were made. The acceptance of the Soil Protection Act (1987) and the Interim
Soil Pollution Act (1983) were crucial to the position of soil policy in that episode
(regulative dimension). Conceptually, soil policy, as well as the standards derived in
the first episode (reference values), was based on the principle of a multifunctional
soil quality, a principle widely accepted in environmental policy, as it connected to
basic environmental policy principles as described in the Priority Memorandum on
the Environment (Urgentienota Milieuhygiëne). Through the development of the
standards, interdependence between science and policy grew and was manifested by
the establishment of the TCSP and the establishment of large government-funded
research programmes, notably the Netherlands Integrated Soil Research Programme
(SPBO). Together with the developing relation between science and policy, the
rivalry between the different ministries concerning the issue of authority charac-
bw.souren 18-09-2006 15:47 Pagina 79
terised the normative dimension of the context within which the reference values
were developed.
In the years following the sensational disclosure of heavily polluted sites in the
early 1980s (see Chapter 1), the number of potentially polluted sites increased
steadily. The size of the problem (of polluted soil) increased and outnumbered the
estimations used to legitimise government expenditure for soil treatment. A major 79
problem that began to trouble the policy field was its stagnating performance; new
chapter 4
cases of polluted sites were reported regularly, while the treatment of sites was far
more expensive and technically far more complex than reckoned with. The problem
increased rather than decreased. This called for reflection on past performance, on
the fundamentals of soil policy and urged for improvement and renewal. The reflec-
tion and renewal of soil policy produced a constant flow of reports, analyses, advice
and assessments. In several of these reports, the ambitious principle of multifunc-
tionality, the guiding principle of soil policy, came under attack. Initially, proposals
for the reduction of the size (and costs) of soil pollution concentrated on the stream-
lining of procedures (Stuurgroep Tienjarenscenario bodemsanering 1989). Later,
new concepts were introduced; the risk approach (Min.VROM 1989b), the active
soil management approach (Werkgroep Bodemsanering 1993), and finally the func-
tion-based approach. Besides this criticism on the cognitive concept underlying soil
policy, criticism on the role of national government was elicited by the Association
of Netherlands Municipalities (VNG) when the Interim Soil Pollution Act was inte-
grated into the Soil Protection Act (VNG 1992).
At the same time, amidst these reconsiderations, progress was made with the
promise of effect-oriented soil quality standards. In the previous episode the reference
values for soil quality, as a first attempt to derive ecological effect-oriented standards
had been developed and published in 1988. The suggestions for improved effect-ori-
ented standard setting (Denneman et al. 1985) and presented at the Symposium on
Soil Quality in 1986 (VTCB 1986c), got more and more hold as results from the
research programme SPBO became available. The introduction of the risk approach
in environmental policy coincided with this and made a number of initiatives fit
together resulting, amongst other deliverables, in new standards. The detailed devel-
opment of effect-oriented standards in this episode is the subject of Chapter 6.
The fractioned, stepwise development of the legal framework for prevention and
treatment of soil (Soil Protection Act in 1987 and Interim Soil Pollution Act 1983)
was perceived as a potential threat to the coherence of policy. In the first episode the
Preliminary Soil Policy Plan was prepared by the ministry to bridge the gap until
the acceptance of the Soil Protection Act. In the second episode, the Minister of
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Housing, Spatial Planning and the Environment installed a steering group in which
the Association of the Provinces of the Netherlands (IPO), the Association of
Netherlands Municipalities (VNG) and the Ministry of Public Housing, Spatial
Planning and the Environment (VROM) were represented. Similar to the
Preliminary Soil Policy Plan, this steering group had to produce a future perspective
80 for soil policy. The difference between that Preliminary plan and this initiative is
that this Steering Group consisted of a number of actors outside the ministry, rep-
Solidified regulatory practice
resenting the actors that played a significant role in the implementation of soil pol-
icy. This difference typifies the first and second episode; whereas in the first episode,
the ministry set the contours for soil policy, asking advice from the VCRMH,
Health Council, and TCSP, in this second episode, actors outside the Ministry were
more explicitly involved in setting the contours for soil policy. The steering group
’10-Year-Perspective’ was asked to produce a scenario for the ten years of soil poli-
cy ahead. Its report was produced in 1989 (Stuurgroep Tienjarenscenario bodem-
sanering 1989) and was the herald of a new stage in soil policy development in
terms of the actors involved in decision-making and standard setting. Underlying
the advice were inventories of potentially polluted sites by the provinces, which had
assessed the size of the problem of soil pollution. These inventories suffered from
methodological difficulties (criteria for assessments differed per authorised authori-
ty, the mobility of substances, the heterogeneity of the soil, and the technical com-
plexity of taking and measuring soil samples) allowing only a rough estimation of
the size of the cleanup operation. Irrespective of these methodological differences,
the actual size of the problem turned out to be much larger than assumed in the
early 1980s when the soil treatment operation started:
Evidently, 6,000 sites will have to be treated. About 100,000 industrial sites may be polluted in
which case they have to be treated and a still unknown area requires measures while it is impos-
sible to estimate the costs of prevention of further pollution.
(Stuurgroep Tienjarenscenario bodemsanering 1989 p.35)
At the start of the cleanup project, total costs were estimated at 60.5 million. Until
1988, approximately 750 sites were treated at a total cost of already slightly over 60.5
million, provided by national government. Costs of privately funded treatments were
estimated at similar amount. The financial burden of soil pollution became high,
unacceptably high according to some. The steering group explored ways to reduce this
burden. Would it be a matter of renewing the guiding principle of multifunctionality,
which had led to such stringent standards for cleanup? Would it be a matter of loos-
ening the priority given to the ecological function as the most vulnerable?
Alternatively, administrative and legislative procedures for cleanup and sanctioning for
pollution could be revised, the legal sanctions for pollution could be increased, and
making polluters pay for the treatment. The steering group was clear in its advice to
bw.souren 18-09-2006 15:47 Pagina 81
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location-specific conditions under which ICM (isolation, containment, monitoring)
measures would do (see Section 4.1.1 on the Soil Protection Act). Furthermore, and
in the same line of reasoning, the steering group stressed the importance of further
development of preventive measures and to be stricter on ‘the polluter pays principle’
as a means to reduce the financial burden for the national government. The steering
group also lobbied for the identification of the polluter, and for a shift in the role of
the government from financial backer to a guardian of soil quality. The suggestions in
the advice triggered the Ministry to install a working group in which the same actors:
the Ministry of Public Housing, Spatial Planning and the Environment, the
Association of the Provinces of the Netherlands (IPO), and the Association of
Netherlands Municipalities (VNG), were represented (in the text referred to as the
Welschen Working Group, named after its chairperson) (Werkgroep Bodemsanering
1993). The Welschen Working Group’s task was to translate the strategic advice of the
‘10 Year Perspective’ Steering Group into practice and to propose solutions for opera-
tional problems. The Welschen Working Group prepared an advice and suggested a
variety of renewals of soil remediation practice under the heading of ‘active soil man-
agement’. This ‘active soil management’ was in fact the formulation of an approach
already applied in practice. The working group summarised active soil management as:
The total of activities in an area geared towards adequate and effective management of structural
pollution and its consequences.
(Werkgroep Bodemsanering 1993 p.22)
9 Basically, the classification is used to prioritise and set up a working programme for the remediation of polluted
sites. It is based on an assessment of the actual and potential risk to ecosystems and human health.
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In this report, new remediation techniques like on site cleanup techniques10, were
promoted. In general, these techniques are less expensive because they do not require
transport and storage of polluted soil while results are promising. In situ techniques
enable treatment ‘on the spot’ and fitted in well with the concept of active soil man-
agement. The development costs of these techniques were foreseen to be high and,
82 correspondingly, it was advised to develop a research programme. In 1994, a new
research programme (NOBIS) was set up (see episode 3 for more details on this pro-
Solidified regulatory practice
gramme). The reports of the steering group and the working group placed soil reme-
diation in a different, more pragmatic, perspective; besides environmental interests,
economic and societal interests would have to be included in the assessment of soil
quality and in determining the remediation target11.
10 On-site remediation.
11 This is one of the central issues of policy renewal in the third episode.
12 Isolation, Control, Monitoring. This was an alternative treatment to be used if specific local conditions (tech-
nical, financial, environmental) were met.
bw.souren 18-09-2006 15:47 Pagina 83
in general results in less strict targets for treatment. Using ICM measures too often
would erode the strategic principle of multifunctionality, and, as the VNG argued,
undermine it. The VNG came up with an alternative, operational approach. Instead
of adopting generic standards and policies, the VNG proposed to differentiate
between functions of soil and established targets for cleanup related to the current
function (or land use) and to the background values (concentration of substances 83
already present in relatively undisturbed areas, due to natural occurrence or to dif-
chapter 4
fuse deposition). Their reports (VNG 1992; Werkgroep Bodemsanering 1993)
pointed out that for the development of effective and efficient soil policy, location-
specific conditions probably mattered more than generic conditions. As such, this
was a criticism on the guiding principle of multifunctionality that was explicit
about generic soil quality; soil quality had to be similar (taking into account differ-
ences in soil type) throughout the country, irrespective of actual land use. With this
document, the VNG interfered with the development of policy and standards that,
until then, was dominated by national government, i.e., the Ministry. The report
also implied criticism concerning the government’s dominance and it turned out to
be the prelude to the reconsideration of the roles of the different governments that
came into full force in the third episode.
The ministry received the critical message and responded with a document:
Location-specific circumstances (Notitie locatiespecifieke omstandigheden)
(Min.VROM 1992), in which the possibilities to apply location-specific measures
(qualifying for ICM measures) were explained in more detail. This was an attempt
to call a halt to the erosion of the principle of multifunctionality as predicted by the
VNG. In addition the Ministry formulated a further underpinning of the generic
reach of soil policy and standards.
Generic principles cannot be made specific to the degree that they can be applied in any possible
case. First, such differentiation may lead to unbridgeable scientific problems, as no models are at
hand that can adequately cover the variety of location-specific circumstances. Secondly, such
framework of standards would be obscure and little user-friendly. Thirdly, very detailed and dif-
ferentiated regulation and standard setting would be in contrast to the effort for deregulation
and decentralisation.
(Min.VROM 1992 p. 8)
In this text, the tension between generic standards and effect-oriented policy was
explained; the generic character concealed in standards conflicts with the local and
actual manifestation of effects. Having identified this inherent inconsistency, the
document continued and provided two strategies to solve this: uniformisation of
criteria and uniformisation of procedures
bw.souren 18-09-2006 15:47 Pagina 84
This [refers to text above, AS] is not to say that uniformisation inevitably cedes to flexibility.
Different uniformisation strategies are thinkable that still allow for location-specific approach.
Uniformisation can apply to criteria for decision-making.
(Min.VROM 1992 p. 8)
84 The importance of the policy document is twofold. Firstly, it was acknowledged that
there is an internal inconsistency between effect-oriented policy and the use of gener-
Solidified regulatory practice
Besides the reflection on past performance, the publication of the risk approach
marks the beginning of the second episode. In 1989 it was introduced in Dutch
environmental policy in ‘Premises for Risk management’ (Min.VROM 1989b), a
seminal document attached to the National Environmental Policy Plan (NEPP) 85
(Min.VROM 1989a). Environmental policy and standard setting since 1989 were
chapter 4
permeated with the concept of the risk approach. Characteristic of this concept was
the notion that societal development has unavoidable adverse effects. The risk
approach included assessment of the extent, reversibility and acceptance of these
adverse effects, and the development of strategies to minimise and manage these
effects. The risk approach was developed to be the
…ruler for effect-oriented environmental policy. Risk criteria indicate the upper (maximum tol-
erable risk) and lower (negligible risk) limit.
For substances in the environment, the document states that the upper limit is reached when
the concentration of a substance equals the calculated concentration of the substance at which
95% of the species present in an ecosystem are protected. The negligible level equals 1% of the
upper limit.
(Min.VROM 1989b)
The risk approach translated into two concentration levels of potentially toxic sub-
stances: the upper and negligible risk levels. The details of this translation are dis-
cussed in more detail in Chapter 6, which analyses the labelling of usable knowl-
edge for the calculation of these upper and negligible levels. The risk approach dis-
tinguished between the effects on human health and effects on ecosystems. For the
calculations of risks to human and ecosystem health, different calculations and
methods were used. The most vulnerable of the two determined the risk level. The
determination of effect levels for human health has its own scientific and policy
background. It is not treated in further detail here. The notion of risk combined
well with statistical techniques, because probability and uncertainty are at the heart
of statistical techniques. Statistical techniques flourished and were used to develop
models to calculate maximum acceptable or tolerable levels of substances (extrapo-
lation models, regression techniques). What has become known as the ‘risk
approach’ in Dutch environmental policy comprised policy concepts as well as the
scientific models applied to calculate standards like target and intervention values
(see Chapter 6). The risk approach and its operationalisation in ‘upper and negligi-
ble risk levels’ was criticised by the Central Council on Environmental Protection
(CRMH) in 1992 (CRMH 1992). The CRMH disagreed with the concept of neg-
ligible levels and its arbitrary operationalisation as 1% of the upper risk level.
bw.souren 18-09-2006 15:47 Pagina 86
…taking into consideration our critical comments to the 95% standard, for the moment it
seems to be wise to ‘assess’ the state of ecosystems by using indicator species, taking into account
that at present the technical means and scientific knowledge to do better are lacking.
(CRMH 1992)
This proposal to use indicators rather than standards could be interpreted as a sig-
nal that the CRMH was critical about standards as instruments in effect-oriented
environmental policy favouring the use of indicator species. However, upon close
reading, the CRMH proposes indicator systems as a second best option to be
applied in case of insufficient knowledge to develop standards. This critical com-
ment of the CRMH is similar to its comments on the Memorandum
Environmental Health Standards written down by the VCRMH in 1977 (VCRMH
1977). In 1977 the VCRMH was critical about the implicit assumption that suffi-
cient scientific knowledge would be available for the development of the environ-
mental quality standards that were announced in 1976. More than a decade later,
the CRMH was still critical about the suggestion to avail of sufficient scientific
knowledge for the development of standards for soil quality. In addition, the
CRMH pointed out five more problems in the risk approach:
The introduction of the risk approach changed environmental policy in many ways.
It was a revolutionary new development in environmental policy. In contrast to
what has been said about the role of scientific knowledge in the development of
standards in the previous episode (Section 4.1.4 and 4.1.5), in this episode scientif-
ic knowledge is indeed very important to provide legitimacy to the new policy
course. Collingridge and Reeve (1986) argued that the role of science in incremen-
bw.souren 18-09-2006 15:47 Pagina 87
chapter 4
environmental policy fields.
The 95% species protection level in the definition of the risk approach as given in
Section 4.2.3 stemmed from the work on species sensitivity distributions (SSDs).
The use of SSDs as a scientific basis for the calculation of risk levels for ecosystems
rested on three assumptions. First, the ecological function of soil is a derivative of
the functioning of the soil ecosystem. The second assumption was that structure of
ecosystems determines the functioning of ecosystems. In bringing to the fore this
assumption, the then prevailing paradigm about the relation between ecosystem
functioning and structure was introduced. The third assumption underlying species
sensitivity distributions was that whenever the species composition is not seriously
affected, there is no serious risk to the structure of the ecosystem. Figure 4.2.1 sum-
marises the line of reasoning. The problem of operationalising ‘serious risk to func-
tional characteristics of soil’ has been shifted towards operationalising serious risk to
the species composition of soil ecosystem.
Figure 4.2.1 Operationalisation of ‘Serious risk to functional characteristics of soil’ (Denneman and Van Gestel 1990 p. 7).
bw.souren 18-09-2006 15:47 Pagina 88
in the previous episode. The programme was prolonged and continued until 1994.
In 1993, two evaluations of this programme were published (KNAW 1993; RMNO
1993). The first, conducted by the Dutch Royal Academy of Science and Arts,
addressed the scientific achievements of the programme. The evaluation was very
positive. The second evaluation was conducted by the RMNO, the advisory coun-
cil that had provided the basis for the programme, as explained in the first episode.
The RMNO was similarly positive about the scientific achievements, but was crit-
ical about the achievements of the programme for the further development of soil
policy, and for the progress of soil cleanup. The advisory council urged to continue
the exchange of research findings by ‘topping-up projects’ (Rogaar 1993), or
through workshops and meetings. In addition, the council advised to develop
expertise and research into policy and administrative studies. Apparently, scientists
were somewhat uncomfortable with the criticism from the advisory council and
they pointed out their achievements as well as the proposed improvements:
We managed, (…) to restructure the initially fragmented and uncoordinated research on soil
quality and pollution by a joint effort of organisations and institutions. It turned into a network
with intense contacts and the willingness to share tasks. Research as initiated by SPBO increased
insight into the functioning of the soil ecosystem and was internationally respected.
(Bolt 1993)
One of the most difficult parts of SPBO was the transfer of findings to policy. (…) Crucial is
that the results of SPBO will be taken up in practice: the next phase (1994-1997) is therefore
geared towards implementation. The end users must be actively involved.
(Eijsackers et al. 1993)
The critical message submitted by the RMNO supported the plans that already
existed for the research programmes ahead: these programmes focused more on
practical techniques for cleanup (NOBIS: 1994-1998), or, as desk studies, on trans-
lating findings to practice (PGBO: 1996-1999). SKB, the later research programme
(1998-2003), was structured as a partnership programme with public and private
parties co-funding research and implementation. However, as we will also see in the
third episode, the suggestion to develop expertise on policy studies was not includ-
ed. My interpretation is that in these research programmes, the course was set by
bw.souren 18-09-2006 15:47 Pagina 89
scientists focusing on the scientific analysis of the problems with a blind spot for
policy and decision-making procedures as subjects that would deserve research
efforts. We will also see in the third episode that suggestions to include a social sci-
ence research programme within SKB do not get any further than the initial docu-
ments setting a proposed outline of an ambitious programme.
Under the flag of SPBO an annual symposium was organised and a journal was 89
published. The annual symposium was organised for the first time in 1988. Initially,
chapter 4
it was meant to be a platform for scientists participating in SPBO, to meet and
exchange knowledge. Since the start of PGBO in 1995, efforts were made to involve
policymakers and private parties, such as consultancies and other companies. The
attempts were successful, and the Annual Symposium became a prime meeting
place for knowledge exchange and networking. The participants’ backgrounds and
affiliations are varied. A survey held at the 10th meeting in 1998 revealed the impor-
tance of the meeting with regard to knowledge exchange and networking by both
scientists and policymakers (Souren et al. 2000). The ‘Bodem’ journal was first pub-
lished in 1991, following an initiative of the programme secretary of the SPBO. It
is a professional journal that finds its contributors and readers among the several
actors involved in soil policy. It covers soil policy in a broad sense. Soil protection,
soil treatment, policy developments, scientific findings and experience from cleanup
projects. An agenda section is included, as well as a section in which new reports
and developments are signalled. At the title page of each article, a photograph is
provided of the author, as well as his or her affiliation and some key information
about his or her expertise. Such information also helps the networking function of
the journal. Contributions are reviewed by the members of the editorial board
recruited from active participants that know about the developments and who are
embedded in a large network of policymakers and the different government levels.
The journal is still being published (2006).
The policy document entitled: Environmental quality objectives soil, water (MIL-
BOWA) (Min.VROM 1991) became the first product of a large policy programme
Setting Integrated Environmental Quality Objectives (INS). The research was con-
ducted at the National Institute for Public Health and the Environment (RIVM).
In a number of subprojects, environmental quality objectives were derived for sub-
stances in soil and water. The research was supervised by a scientific supervisory
committee. The results of the research were reported to the interdepartmental work-
ing group Setting Integrated Quality Objectives (IWINS). Advice on the reports
was provided by the TCSP and the Health Council.
bw.souren 18-09-2006 15:47 Pagina 90
90 Lowest value
Advisory value
Policy considerations
Figure 4.2.2 Procedure to derive integrated environmental quality objectives. Above the dashed line is the scientific underpinning,
below the dashed line the policy process to set the standards (Gezondheidsraad 1995).
This policy project was meant to further the harmonisation of environmental policy.
It provided the window of opportunity to proceed with the further harmonisation of
environmental quality standards for air, water, soil and radiation. Environmental pol-
icy used to distinguish between the different environmental compartments. Water,
soil, air and radiation each had their own specific background and history, making it
difficult to integrate the respective policies. Integrated standard setting refers to the
integrated approach of all compartments. Tuning standards to the various environ-
mental components triggered the development of a specific category of models: mul-
timedia models. It should be observed that the procedure to arrive at standards in
Figure 4.2.2 (repeated from Figure 1.3b) illustrates the relation between scientific
knowledge and policy for standard setting. The proposed procedure reflects a realistic
view on policy development and is informative about the formal representation of the
relation between science and policy in setting standards.
In this second episode, criticism with regard to the guiding principle of multifunc-
tionality grows. The criticism is not focused on this concept as a cognitive concept,
but concentrates on the practical and financial problems of implementing it. The
initial vagueness of the concept that explained its successful role in establishing a
joint science and policy community in the first episode (see my interpretation about
bw.souren 18-09-2006 15:47 Pagina 91
this in episode 1) turns into its weakness in this second episode. It has not been suf-
ficiently translated into operational concepts and measures, causing immediate
implementation problems. Parallel to this criticism, two new concepts develop: the
risk approach as a cognitive concept, and active soil management as a management
concept in which the implementation of soil policy is the central concern. The lat-
ter concept has not yet been explored in full, but will return prominently in the next 91
episode. Not surprisingly, active soil management is brought to the fore by the gov-
chapter 4
ernment actors most involved in the implementation of soil policy: the Association
of Netherlands Municipalities (VNG). It also criticises the generic nature of the
principle of multifunctionality. The VNG pleads for a location-specific and land-
use based approach for the development of soil quality standards (a functional
approach). The second episode is summarised in Table 4.2.1.
Table 4.2.1 The three dimensions of the institutional context in the second episode. For each dimension
critical events, achievements and developments explained in the text above are given in the table.
Regulative • Integration of Interim Soil Pollution Act and Soil Protection Act
(1994)
Cognitive • Risk approach
• Multifunctionality
Normative • Active soil management
• Increase in number of actors involved in policy development
(notably the VNG, the IPO)
• Integration of environmental policy fields
• Criticism with regard to abstract and insufficiently operational
principles guiding soil policy
• Soil research programme (Netherlands Integrated Soil Research
Programme SPBO)
Section 4.2 described the developments since the acceptation of the Soil Protection
Act in 1987 and the publication of the reference values in 1988. In 1994, the
Interim Act Soil Pollution was integrated into the Soil Protection Act. Curative and
preventive soil policy was integrated into one regulatory framework and target and
intervention values were developed, which were initially indicated by A values, later
by the reference values and the negligible risk level (target values). The inclusion of
the Interim Soil Pollution Act decreased the authority of the regional governments
to decide about targets for treatment of specific local sites and in many cases this
resulted in stagnation of cleanup. The VNG’s report, discussed in the previous
bw.souren 18-09-2006 15:47 Pagina 92
episode, was a reaction to this. In the third episode the VNG further successfully
uttered its concern about the standards setting and policy process. Processes and
activities that required an assessment of soil quality stagnated because of the com-
plex procedures and strict standards. In addition, urgent cases of soil pollution that
posed risks either to human or ecosystem health were not cleaned as planned,
92 increasing the environmental risks. The stagnation made soil policy vulnerable to
criticism from other outside the policy field as well.
Solidified regulatory practice
In the episode described in this section, the reflections and proposals for renew-
al as discussed in the previous episode were implemented. These renewals concerned
the cognitive and normative dimensions and took place within BEVER, a Dutch
acronym referring to BEleidsVERnieuwing Bodemsanering (Renewal of soil pollu-
tion policy). Flanking BEVER, several reports appeared that are discussed here.
Besides these developments in policy, research programmes are discussed. Together
these developments in science and policy provide the institutional context for devel-
opment of soil remediation objectives (SROs).
In 1995, the renewal of soil policy was started. A crucial report that paved the way
for the policy renewal was an analysis by the Association of Netherlands
Municipalities (VNG) published in 1995. This document (Moet and Peters 1995)
took a radical different perspective on the issue of soil pollution. The authors
analysed the problem of soil pollution from the perspective of municipalities.
Municipalities integrate societal, spatial, planning and economic perspectives in
decision-making about housing, for instance. In the VNG’s analysis, soil pollution
affects the possibilities and constraints for housing, building and construction
works. Municipalities have a legal responsibility to assess soil quality at building and
construction locations. The legal framework (Housing Act and the Spatial Planning
Act) for building and construction prescribed that risk assessment would have to
take into consideration human health. The existing assessment scheme for soil qual-
ity was developed in soil protection policy and included soil quality standards based
on effects on human health, ecosystem health, and risks of diffusion of pollution.
These standards were tighter than required for a risk assessment for building and
construction. The VNG report made it very clear that the environmental perspec-
tive that had dominated the development of soil policy, and the development of
standards for soil policy in particular, was deemed inadequate from the perspective
of local government. For municipalities, spatial planning and economic perspectives
to soil quality were equally important. Soil quality standards were originally not
developed for that purpose and came under attack by the widening up of the poli-
cy fields in which they were implemented. The report continued with the policy
bw.souren 18-09-2006 15:47 Pagina 93
consequences of a study conducted by the National Institute for Public Health and
the Environment (RIVM) (Bockting et al. 1994a, 1994b, 1994c). That study, com-
missioned by the Association of Netherlands Municipalities (VNG) and accorded
by the Ministry of Public Housing, Spatial Planning and the Environment
(VROM), was meant to develop an assessment scheme for soil quality to be used by
municipalities while applying the Housing Act and the Spatial Planning Act. The 93
resulting assessment differentiated between four land-use types, based on exposure
chapter 4
to soil pollution, and proposed standards for each land-use type.
• Housing with garden with vegetable garden (50% of consumed potatoes and
100% of consumed vegetables assumedly come from this garden)
• Housing with garden (10% consumption from this garden)
• Recreation and public green space
• Housing without garden, infrastructure, construction works
The report by the VNG made explicit the role of soil quality standards from the
perspective of local government. With this document, the VNG set the scene for a
drastic renewal of soil policy. Policy renewal should be geared towards the practice
at the regional and local government level. Multifunctionality had become the guid-
ing principle not only for soil policy, but also for the development of the standards.
With this criticism by the VNG on the inadequacy of the standards, the principle
of multifunctionality was attacked, and with that, the basis for existent soil policy
as developed since 1971. The renewal of soil policy now was no longer a paper pro-
posal, but was getting implemented as BEVER started in 1995. Section 4.3.2
describes the development of BEVER and the interdepartmental policy study by the
Soil Remediation Working Party.
The first aspect; ‘from sectoral to integral’ referred on the one hand to the further
harmonisation of environmental quality standards for the different environmental
compartments that was started since the introduction of the risk approach in 1989.
On the other hand, it referred to the integration of the policy fields of sectoral envi-
ronmental policy, housing, agriculture and spatial planning. The second aspect con-
cerned the cognitive dimension underlying soil policy. It referred to earlier sugges-
tions to reconsider the basic principle of multifunctionality. These suggestions were
already made in the previous episode, for instance in the report by the Welschen
Working Group (1993). As mentioned in the previous episode, this Working Group
had coined the concept of ‘active soil management’ as an additional or alternative
concept in soil policy. The third aspect related to a tendency in policy to shift focus
from a project approach to a process approach. For instance, process-related stan-
dards and protocols were introduced in soil policy. The fourth aspect referred to the
manifestation of the IPO and the VNG as mentioned above. Besides their report in
1995, the VNG had already brought forward an alternative approach to the inter-
vention values in 1992 (see Episode 2 (VNG 1992)). The fifth aspect had also been
mentioned before by the Welschen Working Group (Werkgroep Bodemsanering
1993) as a possibility to involve more private parties in the financing of soil treat-
ment operations, thus reducing the burden for government. The sixth aspect is
related to the fourth in the sense that it is a plea for a more open and participatory
process involving more actors.
After the publication of the Target Perspective, a Working Group was composed
to implement it. For a further understanding of this policy renewal it is important
to recall the aims of the policy renewal. The renewal of soil policy aimed to take
away causes of stagnation, to reduce the costs of treatment and to increase the
progress of cleanup. The Target Perspective marked a shift at the cognitive dimen-
sion (a function-based approach was introduced as an alternative or complementa-
ry to multifunctionality and the risk approach). It also marked a shift at the nor-
mative dimension as it explicitly addressed the relation between the different gov-
ernment layers. The Working Group produced a working plan resulting in four
projects (BEVER 1, 2, 3, and 4, (Min.VROM et al. 1996)Of these, BEVER 1
specifically addressed the conceptual orientation of the new policy and its instru-
ments, including the development of new standards. BEVER 2, 3, and 4 concerned
administrative, financial, and legal procedures and quality control mechanisms. As
bw.souren 18-09-2006 15:47 Pagina 95
the focus is on the development of soil quality standards, only the BEVER 1 proj-
ect is discussed here in more detail.
The project results of BEVER 1 were published in a report by Witteveen+Bos in
1997 (Witteveen+Bos 1997). The report contained a reflection on assumptions in soil
policy and standards. One of the most revealing illustrations is (slightly modified for
clarification) included here in Figure 4.3.1, which shows that the problem of pollut- 95
ed soil is shared by three policy fields: Spatial Planning, Environment and Economy.
chapter 4
Env
g
nin
iron
lan
me
ial p
nt
t
Spa
Polluted
Soil
Economy
Figure 4.3.1 Polluted soil visualised as shared by three policy fields: Environmental Policy, Spatial planning and Economy
(Witteveen+Bos 1997).
Figure 4.3.1 illustrates what the VNG has written before in the reports discussed in
the second episode (VNG 1992) and what (Moet and Peters 1995) discussed above.
The first part of the BEVER 1 project document argued that presently the devel-
opment of soil policy was ‘located’ in the ‘environment’ wedge of the pie, while in
implementation at local and regional levels, soil pollution had spatial planning and
economic consequences. The visual representation of the position of soil policy at
an overlap between three policy fields opened up new vistas for soil policy that were
further explored in the document. The second part of the document hence focused
on the development of such future and alternative course for soil policy, where it
would be recognised that soil was no longer only an environmental compartment,
but also an economic and social resource. This recognition, it was argued in the
report, required the integration of environmental policy and spatial planning
approaches towards soil. The report compared the six aspects from the Target
Perspective to existent approaches in Environmental policy and Spatial Planning
and identified two approaches; the existent, top-down target-driven approach and
a consensual, process-oriented and participatory approach. The renewal of soil pol-
icy in the BEVER project aimed at a move into the latter direction. The document
bw.souren 18-09-2006 15:47 Pagina 96
To date, soil pollution policy is characterised by its hierarchical top-down approach with a clear
normative perspective.
(Witteveen+Bos 1997)
These quotes illustrate that the policy renewal concerned a renewal of the relations
between involved parties, i.e., the normative dimension. In the BEVER 1 report,
the second aspect of the Target Perspective (From multifunctional to function-
based) was not treated in detail. Remarkably, the BEVER 1 project, meant to dis-
cuss the conceptual direction of soil policy, produced an uncritical analysis that
focused on the normative dimension and was geared towards a reconfiguration of
the involved policy fields and policy levels. A reconsideration and further specifica-
tion of the principle of multifunctionality would have been possible, but it was
rejected and replaced by a new approach, one that was more specific about the rela-
tions between involved parties. The cognitive and normative dimensions of soil pol-
icy were not analytically distinguished as such in the report. Rather, they were used
as similar and conceptually equal.
By the time the BEVER 1 project was conducted, a policy study by the
Interministerial Working Group Soil Remediation (Interdepartementale Werkgroep
Bodemsanering 1997; Staatscourant 1996) was reaching its gloomy conclusions. The
high (650 million estimated in 1997) and ever-increasing remediation costs (a hun-
dred million euros annually, estimated in 1997) called for action. With an annual
expenditure of 60,5 million, the cleanup operation would take a hundred years.
There will be no option but to leave following generations with a legacy of serious soil pollution.
(Interdepartementale Werkgroep Bodemsanering 1997 p. 3)
This interministerial study proposed to reduce the size of the problem by reconsid-
ering the cleanup objectives; i.e., abandon multifunctionality as the objective of
treatment. Instead, the new treatment objective would be function-oriented and
cost effective; that is, the function (land use) would determine the treatment objec-
tive. Two policy alternatives were developed for cost effectiveness. The first alterna-
tive was called the ‘environmental returns alternative’ and it implied that:
bw.souren 18-09-2006 15:47 Pagina 97
The environmental returns from the cleanup measures are of central importance. This means
that the appraisal must result in establishing the most desirable and cost-effective cleanup result
from an environmental point of view.
The second alternative was called the ‘returns on user alternative’ and it implied
that: 97
chapter 4
This alternative means in practice that, for example, the owner of a polluted industrial site
removes as much pollution as to make the environmental risks associated with its current use
permissible again unless he deems it in his interest to remove more pollution, for example, to
increase the selling value of the site. If the soil is to be used later for a more sensitive function,
the site will have to be cleaned up again.
(Interdepartementale Werkgroep Bodemsanering 1997)
A calculation was made of the reduction in costs of the two alternatives compared
to present practice. This revealed that the first alternative (the environmental
returns alternative) would reduce costs by 35%. The second alternative (returns on
user alternative) would reduce costs by 50%. The policy study left the two alterna-
tives open for consideration. In the concluding section, the working group stressed
the regional nature of soil pollution issues and the need to de-centralise soil policy.
The report concluded that:
Active soil management… could result in the advocated integration of soil remediation into
social processes.
(Interdepartementale Werkgroep Bodemsanering 1997)
In other words, soil was also reframed in this document. Soil was framed in the
report as a resource for social and economic growth. Soil pollution was reframed as
more of a social, economic and spatial planning problem than an environmental
compartment, as documents in earlier episodes showed. This study was in line with
the BEVER 1 report in the sense that it suggested a shift from an environmental
perspective towards a Spatial Planning perspective. Where the evaluation by the
Welschen Working Group, discussed in the previous episode, (Werkgroep
Bodemsanering 1993) had ‘protected’ the guiding principle of multifunctionality,
the present report ‘Good ground for growth: new incentives for soil remediation’
proposed to abandon it and replace it with active soil management as a guiding
principle, including a land use based approach to soil quality standards. The work-
ing group also included an analysis on knowledge infrastructure. It underlined the
conclusions of the report by the Committee on Coordination and Co-financing of
Soil Research CCFBO (Commissie coördinatie en co-financiering geïntegreerd
bodemonderzoek 1996), to set up a platform (SKB, Stichting Kennistransfer
bw.souren 18-09-2006 15:47 Pagina 98
Bodem) where supply and demand for scientific knowledge could come together.
This CCFBO report is discussed in Section 4.3.6.
Compared to the previous episodes a shift took place with respect to the fram-
ing of soil and soil pollution. In the first episode, the Ministry of Public Health and
the Environment had successfully and with great effort framed soil as an environ-
98 mental compartment. Remember the efforts to develop an overarching Soil
Protection Act under the responsibility of the Ministry of Public Health and the
Solidified regulatory practice
Environment as described in the beginning of this chapter. In this third episode, soil
was reframed, out of environmental policy and into the realms of economic and
spatial planning policy. It might have to do with the merger between the Ministry
of Public Health and the Environment and the Ministry of Public Housing and
Spatial Planning (in 1982) causing a reframing of the issues within the new
Ministry, but from the documents published in this episode it seems that imple-
mentation problems experienced at local and regional governments were decisive.
The shift in the guiding principle for soil policy (from multifunctionality to land
use based) was motivated by referring to the practice related to the concept of active
soil management, not to the content of these concepts. This further supports the
interpretation that the renewal at the cognitive dimension, as proposed in the above
interdepartmental policy study, was meant to facilitate the renewal of the normative
dimension that was elaborated on in detail in the BEVER 1 report. The origin of
the concept of ‘active soil management’ further supports this analysis: dissent with
the perceived hegemony of the central government compared to local and regional
government. Active soil management promised to facilitate the revision of the role
of central government and the relation between the national, provincial and local
government. Section 4.3.3 examines the concept more closely.
This concept was coined in the report of the Welschen Working Group, mentioned
in the episode 2 in this chapter (Werkgroep Bodemsanering 1993), where, active
soil management was defined as:
The total of activities in an area geared towards adequate and efficient conduct with regard to
the consequences of structural soil pollution.
(Werkgroep Bodemsanering 1993)
The concept grants a central role to activities by different actors, and makes soil
quality subordinate; a certain soil quality is the eventual outcome of activities that
do not exclusively aim at the improvement of soil quality. This focus on activities,
rather than on a stated output of these activities was unfamiliar to many of the
bw.souren 18-09-2006 15:47 Pagina 99
chapter 4
vention-management-treatment-aftercare, with the aim to realise sustainable use of
soil in a socially acceptable manner. In the Second Working Book on active soil
management (Moet et al. 1998), focus was on active soil management as a process.
In the book, quality control of the process and knowledge transfer were identified
as important aspects for the success of active soil management. Active soil manage-
ment was tried by scientists as a guiding concept for research programmes.
A group of scientists and practitioners also explored active soil management as a
guiding concept for future research programming (Ouboter et al. 1996). They for-
mulated it as follows:
All activities required to handle polluted sites with several and diverse bottlenecks (technical,
spatial, organisational and financial).
(Ouboter et al. 1996)
of a remediation case were not affected by the new policy. ‘Only’ the treatment goal
or objective was affected. The Cabinet chose not to select one of the two alternatives
(environmental returns alternative or returns to user alternative) that were developed
by the working group in the interdepartmental policy study. Rather, the Cabinet pro-
posed to develop guidelines for this appraisal process (of effectiveness) in the context
100 of BEVER and decentralised this appraisal process to the local and regional policy
level. Part of the development of this appraisal process was the development of soil
Solidified regulatory practice
The results of the work of Core team A were published in 1999 under the title:
From funnel to sieve. The title of the document refers to the difference between a
funnel and a sieve: the flow of treatment projects can get blocked in case a large
project blocks the funnel. Once a large project blocks the funnel, not even small and
simple projects can pass through. Through a sieve, the relative simple and small
treatment projects can pass, leaving the large and complex projects behind for a cus-
tomised approach. The metaphors of funnel and sieve are used to illustrate the
attempt to reduce the stagnation that can result from the blocking of the funnel by
replacing the funnel by a sieve. The report ‘From Funnel to Sieve’ was meant to set
the boundaries of the playground within which location-specific treatment could be
formulated. The development of new standards, in line with the six aspects of the
Target Perspective (see Section 4.3.2) was one of the main tasks of project A. The
‘old’ soil quality criteria had to be reformulated to be made consistent with and to
facilitate the ‘new’ soil policy. First of all, this required the development of a typol-
ogy of land use. In Chapter 7 this development is explained in detail. Secondly,
standards had to be formulated in each of these land-use types that were related to
bw.souren 18-09-2006 15:47 Pagina 101
the risks to human and ecosystem health. This is also explained in Chapter 7. The
list of soil remediation objectives as published in ‘From Funnel to Sieve’ is repro-
duced here.
Table 4.3.1 Land-use types and soil remediation objectives in mg per kg dry soil. No SROs are derived for
land-use type 3, as it is assumed that there is no exposure (and therefore no actual risk to human health).
101
This land-use type has no ecological requirements, as this land-use type does not aim to support the ecological
chapter 4
function. For land-use type 4 a customised approach is envisaged.
The customised approach to be applied in land-use type 4 was not further explained
in the report. It was suggested to develop a customised approach per case or per area
but the issue was not resolved in the report. The differentiations carried with them
the risk of inequality in terms of soil quality. Location-specific approaches could
result in different soil quality at different sites. Here the legal responsibility of nation-
al government embodied by the Ministry of Public Housing, Spatial Planning and
the Environment to safeguard the generic soil quality urged to demarcate the degrees
of freedom for location-specific treatments. This required further work and specifi-
cation. Another issue that had been identified in the Cabinet’s position that had not
been resolved was the approach for subsoil, i.e., mobile pollution. The concept of
‘stable end situation’ was introduced, to denote that treatment would have to be
geared towards a stabilisation of the plume of mobile pollution, spreading from the
source, but the policy regarding mobile pollution was not yet fully fleshed out.
The TCSP commented on the report and stressed to develop a policy for sub-
soil. It addressed specifically the monitoring and ‘Aftercare of mobile pollution’. In
addition, the committee anticipated a ‘new’ attitude to soil quality, in which envi-
bw.souren 18-09-2006 15:47 Pagina 102
Besides the renewal of policy as described in Section 4.3.5 above, the steering and
programming of research programmes was reconsidered. This reconsideration
matched the tendency in science policy to focus more on market-oriented, pro-
grammatic research programming. The Committee on Coordination and Co-financ-
ing of Soil Research (the Van der Vlist Committee) was commissioned by the the
Ministry of Economic Affairs, the Ministry of Education, Culture and Science, the
Ministry of Public Housing, Spatial Planning and the Environment, the Ministry of
Agriculture, Nature and Fisheries, and the Ministry of Transport, Public Works and
bw.souren 18-09-2006 15:47 Pagina 103
chapter 4
of polluted soil and reduce the costs for central government. In its advice, ‘Soil
Science Applied’ (Commissie coördinatie en co-financiering geïntegreerd bodemon-
derzoek 1996), the committee identified transfer of knowledge from supply to
demand as the bottleneck for the development of applicable knowledge.
An essential part of the R&D structure is the transfer of knowledge. Transfer of knowledge
means: linking the demand for knowledge to the supply of knowledge. Coordination and co-
funding of soil research mainly aim at the advancement of knowledge transfer.
(Commissie coördinatie en co-financiering geïntegreerd bodemonderzoek 1996)
Supply side
• Knowledge supply is fragmented
• Knowledge is insufficiently multidisciplinary
• Knowledge suppliers focus on knowledge production and not on knowledge application
Demand side
• Parties are unaware of and unfamiliar with R&D concepts and strategies
• Parties lack an overview of the available knowledge and are not competent enough to articu-
late research needs
• There are insufficient financial resources
(Commissie coördinatie en co-financiering geïntegreerd bodemonderzoek 1996)
In the first part of the literature review in Chapter 3, it was made clear that repre-
sentations of science and policy as two distinct domains can be functional as an expla-
nation of an ideal type situation, but not as representations of actual practice. The pro-
posal of the committee must therefore be questioned. After pointing out the limited
success of intermediaries, the committee proposed SKB as a facilitator of the cooper-
104 ation between knowledge supply and knowledge demand. SKB would have to bring
together parties in temporary consortia and assist these consortia. This proposal was
Solidified regulatory practice
very much in line with the analysis by Gibbons and co-workers (1994) in their influ-
ential book discussed in the third section of the literature review in Chapter 3. In their
book, the authors identified a shift towards the setup of temporary consortia within
which contextual knowledge was developed to solve the problems identified by the
members in the consortium (Mode 2). The relevant research programmes in the third
episode were PGBO, NOBIS and SKB. These are explained below.
chapter 4
Figure 4.3.3 Organisational structure of PGBO (after (Rogaar 1997)
input and usable knowledge as the output. The translation process was perceived to
be a matter of bringing people together and writing reports in which basic knowl-
edge was translated into knowledge ready for application. It was believed that bring-
ing people together more often, would enhance this translation. Compared to pre-
vious programmes, focus was not so much on the development of new technical
knowledge, but on the translation of existing knowledge and the development of
concepts and strategies. In retrospect, research developed under the flag of PGBO
became geared towards knowledge to manage polluted soil sites and solve complex
problems. In doing so, soil pollution was increasingly framed as a social problem,
instead of an exclusively scientific problem. Projects funded by PGBO were often
conducted by other than academic scientists, who dominated the SPBO projects.
Several studies within PGBO pointed to attention for process management and
knowledge utilisation and the need to involve problem perception and communi-
cation strategies in solving these complex problems (Canter Cremers et al. 1999).
In addition to the development of PGBO, a related trend was to produce knowl-
edge for in situ extensive treatment. This knowledge was developed in NOBIS. The
development of NOBIS was already announced in 1993 by the Welschen Working
Group that drew attention to in situ techniques as these were promising and rela-
tively cheap treatments (Werkgroep Bodemsanering 1993).
…to develop, evaluate and demonstrate innovative strategies, methods and techniques from
biotechnology for in situ treatment and management of contaminated soil.
(Rogaar 1997)
NOBIS was the first programme in which the approach of public and private fund-
106 ing was applied. This approach reflected the shift in perception of the development
of usable knowledge. The research programmes until then (SPBO and PGBO) per-
Solidified regulatory practice
Supervisory Board
chapter 4
Programme
Office
knowledge) and policy (as the demand side). SKB matched owners of a problem
with parties that could contribute to a solution. Scientific knowledge contributed
to the solution of the problem but was not granted the status of ‘exclusive provider
of a solution’ it used to have. Scientists became participants in SKB just like local
governments, local interest parties and private parties. This philosophy reflected the
then prevailing notion of ‘joint and shared’ processes, that we have seen so clearly
illustrated by BEVER. As a research programme, SKB started from a less positivis-
tic approach compared to the dominant approaches in the first and second episode.
In its business plan, SKB, for instance, made it explicit that it was meant to support
the implementation of policy as developed by the Ministry of Public Housing,
Spatial Planning and the Environment. Still, the vocabulary in the business plan
was dominated by ‘supply side and demand side’
When setting up an integrated approach to knowledge transfer it must be borne in mind that
the actual approach to knowledge transfer is not fit for future developments. Actual knowledge
transfer focuses on knowledge distribution, where the supplier of knowledge acts. Alternatively,
specific knowledge should be supplied that answers a precise question. The demander of knowl-
edge becomes the actor. In addition, with respect to soil matters learning instead of passive
uptake of knowledge is important. Within SKB, the principle of information-on-demand and
the transfer of practice and experience needs to be further developed and put into place.
(Van der Vlist et al. 1998)
108
Solidified regulatory practice
Knowledge transfer
Issue knowledge
Issue knowledge
Issue knowledge
Issue knowledge
Issue knowledge
Process knowledge
Technological knowledge
Basic knowledge
Figure 4.3.5 Types of knowledge developed within SKB (Van der Vlist et al. 1998)
opment. The strategies SKB proposed for knowledge transfer further support the
interpretation that SKB was designed according to an instrumentalist perspective:
more exchange, more meetings, more documents, more newsletters as a strategy to
improve knowledge transfer.
109
chapter 4
Geo sciences
Figure 4.3.6 Disciplines and developments (Van der Vlist et al. 1998)
The institutional context in this episode can be characterised as a search for and imple-
mentation of new steering concepts for policy and research. Multifunctionality as the
guiding principle for soil policy is now (in practice) replaced by function-based assess-
ments of soil quality. Active soil management, introduced in the previous episode guides
many of the developments as a management concept. The role of central and de-cen-
tral government is revised, after successful attempts by the Association of Netherlands
Municipalities (VNG) to open up the decision-making and standard-setting processes.
In this third episode, new research programmes are developed that are based on a
changed view on the development of usable knowledge. Public-private funding mech-
anisms and innovative programme organisations are developed. This third episode ends
with the publication of the final report of the policy renewal in 2000.
bw.souren 18-09-2006 15:47 Pagina 110
Table 4.3.2 The three dimensions of the institutional context in the third episode. For each dimension critical
events, achievements and developments that have been explained in the text above are listed in the table.
chapter 5
Chapter 4 described the recent history of soil policy and science. Three episodes
were distinguished. In each of these episodes a new set of standards for soil quality
was developed. In the present chapter, the labelling of usable knowledge for the
development of the reference values in the first episode is analysed. In Chapter 3 the
concepts boundary work, labelling usable knowledge, regulatory practice and institu-
tional context were brought together. The line of reasoning in that chapter was that
the arguments used for labelling usable knowledge had to be related to the dimen-
sions of the institutional context within which these standards were developed in
order to legitimise this labelling. This chapter answers the research questions 2 and
3 for this fist case study:
(Min.VROM 1986). The document was prepared by a small group of policy staff
members and proposed standards for the concentration of metals below which soil
could be qualified as having a good soil quality. These provisional reference values
were based on data from inventories of metal concentrations in soil samples. These
studies were carried out for agricultural lands and ‘relatively undisturbed areas’ in
112 the Netherlands and abroad in the 1970s and 1980s (Edelman 1984; Kabata-
Pendias 1984; Van Driel and Smilde 1981). After publication of the provisional ref-
Reference values for soil quality
A soil that meets the reference values can be considered in general to be multifunctional accord-
ing to the current scientific knowledge; this means that no adverse effects of the specific sub-
stances are expected.
(Min.VROM 1988)
Before proceeding with the details of the case studied, a reiteration is given of some
points from the first episode in Chapter 4, that are of special relevance here. In
1972, the department on Soil was established within the Ministry of Public Health
and the Environment. The department handled a variety of issues that were not cov-
ered by the other departments (Water and Air) within the Ministry. Notably, radi-
ation, noise and toxic substances were amongst these. Only after the discovery of
landfills and waste dumps throughout the country, additional resources became
available to increase staff. Soil protection was rocketed on the political agenda upon
the discovery of a large polluted suburb in April 1980. By then, the head of the
bw.souren 18-09-2006 15:47 Pagina 113
department responsible for soil policy at the ministry was very well aware of the
need to hire staff with technical knowledge on soils. He assigned a significant part
of the research budget to a soil research programme, and involved his staff members
in the supervision of research projects. Also, the TCSP was established in the Soil
Protection Act as an advisory committee to the government concerning technical
aspects of soil policy. At the time of the quest for reference values, the soil depart- 113
ment was an enthusiastic and dedicated group.
chapter 5
In the first episode, soil policy and research gained a position relative to other envi-
ronmental compartments and relative to flanking policy fields like agriculture.
Contacts between science and policy developed and intensified. The development of
the regulatory framework and of the relation between soil scientists and policymakers
was facilitated by the vaguely formulated guiding principle of multifunctionality. This
principle served as a boundary object to unite science and policy. The sense of urgency
to develop a legal framework created a momentum to develop soil standards. In the
early years of environmental policy, standards were already referred to as adequate
instruments to regulate the use of environmental and natural resources.
Table 5.1 The three dimensions of the institutional context in the first episode as described in Chapter 4.
Critical events, achievements and developments are given for each dimension.
This chapter first gives a concise chronological overview of the case, followed by an
analysis of the labelling of usable knowledge.
Before soil pollution became a political and scientific issue, soil was predominantly
perceived as the carrier for civil works on roads, dams and dikes and as substrate for
agricultural production (production function). Relevant scientific research on soils
was concentrated at Wageningen Agricultural University, at the Institute on Soil
bw.souren 18-09-2006 15:47 Pagina 114
Fertility (IB) and at the National Institute for Nature Management (RIN). Focus
was on the abiotic, chemical and physical properties of soils. Scientific findings were
developed in the context of agricultural policy. Knowledge on the effects of poten-
tially toxic substances on the soil ecosystem was limited at that time to relatively
small groups in Wageningen and at the Free University in Amsterdam. At the
114 Institute on Soil Fertility (IB) and the National Institute for Nature Management
(RIN) research was carried out that measured concentrations of metals in soil. In
Reference values for soil quality
1979, a research project was started and conducted by Edelman at the National
Institute for Nature Management. It was funded by the Research Programme Soil
Protection (see Section 4.1.4.) from the Soil department from the Ministry of
Public Health and the Environment. The results of this study were published as a
list of concentrations of metals from the sampled sites (Edelman 1984). At the
Institute on Soil Fertility the researchers Van Driel and Smilde (1981) had assessed
the levels of potentially toxic substances in agricultural soils in 1981. International
studies were available with similar data on concentrations of metals in soils (Kabata-
Pendias 1984). In a speech held in 1986 one of the ancestors of Dutch soil science,
De Haan, summarised the state of knowledge at the time.
While soil biology is [in 1986] a more or less underdeveloped area, soil chemistry and soil
physics have unravelled the abiotic soil processes in depth. An important drive for this was the
increase in knowledge required for the function of soils in vegetable food production.
It is worthwhile to note that physical, physico-chemical and chemical processes have received
much more attention in the past compared to biological processes. This might be related to the
higher complexity of processes within and among living systems and organisms.
We regret this gap in knowledge on these processes now that protection of the environment calls
for quantitative information on these biological processes.
(De Haan 1986 p.18)
De Haan qualified the then current knowledge as insufficient for a proper assess-
ment of effects. In the interim period between this qualification (1986) and the
publication of the reference values in 1988, no significant changes or breakthroughs
in scientific knowledge occurred.
While quality assessment on the basis of effects is not yet possible, and it is also not deemed
wise or correct to suggest that sufficient knowledge is available to do so, … the first steps
towards a quantitative assessment of soils could be taken.
(De Haan 1986 p.18)
bw.souren 18-09-2006 15:47 Pagina 115
Apparently, at the time the reference values were being developed, the available
knowledge did not meet the required needs. Here it is relevant to remember the text
in the policy document ‘Environmental Quality’ mentioned in Chapter 4.
…whenever it is acknowledged that there are gaps in knowledge, it can still be desirable to
develop standards. 115
(Min.V&M 1976b p. 29)
chapter 5
5.3 Setting the standards and labelling usable kowledge
In this first case, the labelling of usable knowledge was not a matter of choosing
between alternative bodies of knowledge. There were simply no alternatives. The
Edelman dataset from the research project at RIN, together with the datasets by Van
Driel and Smilde and comparable international work, represented the body of knowl-
edge available on the concentrations of substances in soil. In this section an explana-
tion is given of this scientific knowledge available at the time and eventually labelled
as usable to develop the reference values. Also, the arguments that are used to connect
the available knowledge to the qualitative wording of the reference values are given in
Sections 5.3.1 to 5.3.3. In addition, the stepwise production of the reference values
with a focus on the scientific models and calculations made to establish the reference
values as they were published in 1988 is described in these sections. Two proposals
were made, before the publication of the third proposal. The following sections also
describe the main differences between the subsequent versions.
The initiative for the development of the reference values and for labelling usable
knowledge was taken by the Ministry of Public Health and the Environment. In
1986, the Soil Protection department published a Discussion Memorandum on Soil
Quality, containing provisional reference values. The staff member at the ministry
who did most of the work for the Discussion Memorandum on Soil Quality made
it clear that he used his scientific training as an ecologist to assess the usability of
the Edelman data (see above). He was surprised about the relative homogeneity of
the data, having in mind the data he collected himself in the research for his PhD
thesis. This is a clear example of the paradigmatic differences between scientific
fields about dealing with variety and uncertainty. Judging the available knowledge
from his ecological perspective made it possible to take the dataset by Edelman into
consideration and evaluate its usability. With his argumentation this scientific
knowledge was labelled as usable knowledge.
bw.souren 18-09-2006 15:47 Pagina 116
C is binding capacity; OM is the organic matter mass percentage and L is the lutum
mass percentage. With this formula, soil types were characterised for their metal-
binding capacity. The relation between lutum and organic matter was assumed to
be independent of the percentage of any of these concentrations. With this formu-
la a continuous system for soil types was proposed. To facilitate comparisons
between different soil types throughout the country, standard soil was defined as soil
with a binding capacity, C equal to 27.
Cstandard soil = 27
Measured concentrations, as well as organic matter and the lutum content of the
samples taken by Edelman were used to calculate metal concentrations in standard
soil using the following formula:
Calculating these concentrations for ‘standard soil’ resulted in a wide range of val-
ues for every substance. The provisional reference values were set at a level that was:
This meant that 90% of the calculated concentrations were below the reference val-
ues. These provisional reference values were published in the Discussion
Memorandum on Soil Quality.
bw.souren 18-09-2006 15:47 Pagina 117
Table 5.2 Formulas for the calculation of the provisional version of the reference values and the values as
calculated for standard soil (Min.VROM 1986).
Cr 30 + 2 L 125
117
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Ni 15 + L 50
Cu 8 + 0.6 L 30
Zn 50 + 3 L 180
Pb 30 + 2 L 100
As 8 + 0.6 L 30
The two modifications resulted in the formulas per substance for the peaty and
mineral soil given in Table 2. The modifications were based on a differentiation
between the two meanings of lutum and organic matter as presented in the textbox
at the beginning of this section. Scientists urged for differentiation where policy-
makers stressed similarity.
118
Table 5.3 Relations between concentrations of elements and lutum and organic matter content for mineral,
Reference values for soil quality
Cr 50 + 2 L 50 + 2 L 100
Ni 10 + 1 L 10 + 1 L 35
Cu 6 + 0.6 L 40 + 0.6 L 55
Pb 35 + 1 L 75 + 1 (L + OM) 110
As 8 + 0.4 L 25 + 0.4 L 35
The two versions (provisional reference values proposed by the ministry and the
alternative developed by scientists in the PTCSP) had in common that lutum and
organic matter content were used as the key soil characteristics to base a standardi-
sation of soil quality on. However, they had different reasons for this. The argu-
mentation in the Discussion Memorandum was that lutum and organic matter con-
tent were crucial to the binding capacity of soils. This is a relevant characteristic
when analysing anthropogenic enrichment on top of the naturally occurring con-
centrations, but not if we consider soils that are sampled from ‘relatively undis-
turbed areas’ that are assumed to contain only, or mainly, naturally occurring con-
centrations. In their proposal, PTCSP started from the notion that the samples were
taken to represent naturally occurring metals, and hence should be understood by
selecting lutum and organic matter because they cater for most of the naturally
occurring presence of metals. For instance, one of the main constituents of miner-
al soils is quartz and quartz naturally contains a high concentration of heavy met-
als. In PTCSP´s advice, focus was on selecting the “right” classification characteris-
tic, according to scientific standards.
Lutum and organic mater content are two important characteristics of soils that
bw.souren 18-09-2006 15:47 Pagina 119
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knowledge about two soil characteristics: lutum and organic matter content.
The capacity of soils to bind cations (positively charged ions that are predominant in fer-
tilisers; heavy metals are often present in the soil as cations) determines the effects of fertiliser
addition or presence of metals on plant growth. Organic matter binds these ions. Depending on
other circumstances these ions become available for plant uptake. Lutum also has this binding
capacity, but far less than organic matter. Binding capacity differs per substance. The mass per-
centages of lutum and organic matter together determine the binding capacity of soils for any
given substance. A low binding capacity of soil implies a high availability for uptake by plants
and animals, as well as a risk of washing out. Sandy soils have a smaller binding capacity than
peaty soils. Therefore, plants can take up potentially toxic substances more easily from sandy soils
than peaty soils. Binding capacity was identified as an important soil characteristic in studies into
the effects of added nutrients and fertilisers on agricultural production. Binding capacity is a rel-
evant characteristic to understand the effects of added substances.
Some metals are present in the rock material from which soils are formed, others occur only
through anthropogenic enrichment. The natural occurrence of metals is, like binding capacity,
related to the lutum and organic material of soil, as these in turn are related to the rock materi-
al from which this soil was formed.
In the case of a natural presence of metals, their concentration is related to the lutum and
organic matter content of soil because they relate to the rock material. In the case of anthro-
pogenic enrichment of metals, their potential effects are related to the lutum and organic matter
content of soil because they determine the binding capacity of soil.
Lutum and organic matter content of a soil translate into the variety of soil types. Clay soils
have a high lutum content. Peaty soils have a high organic matter content. Mineral soils have a
low organic matter content. Sandy soils have a low lutum and a low organic matter content.
The double meaning (binding anthropogenic enrichment and natural occurrence) of lutum
and organic matter content dominated the discussion about the appropriate approach to calcu-
late reference values. Since the production of reference values, this double meaning has become
a millstone for the implementation of standards as it is difficult to establish appropriate relations
to differentiate between the two, and difficult to translate into policy objectives (see for instance
(Van Straalen and Souren 2002) on this issue).
bw.souren 18-09-2006 15:47 Pagina 120
In 1988, the reference values were published. The alternative prepared by the
PTCSP was partly adopted; substance-specific formulas were used but the differen-
tiation between mineral and peaty soil was not adopted. The lumping of the two
120 categories (mineral and peaty soil), implied that for copper and arsenic, both lutum
and organic matter had to be included in the formulas.
Reference values for soil quality
Table 5.4 Formulas for the calculation of the final version of the reference values and the final reference
values as calculated for standard soil (Min.VROM 1988) .
Ni 10 + 1 L 35
Cu 15 + 0.6 (L+OM) 36
Pb 50 + L + OM 85
As 15 + 0.4 (L + OM) 29
Although some scientists were agitated about the final published reference values,
there was also agreement that an assessment was urgently needed. De Haan, as a
prominent member of the PTCSP and leading scientist from Wageningen
University labelled the available knowledge as usable knowledge with the following
statement:
…the increasing degree of soil pollution does not allow for any further delay of legal regulations
for soil protection. And of course, it would be extremely helpful for soil protection to avail of an
assessment framework for soil quality.
(De Haan 1986 p.28)
He referred to the development of the Soil Protection Act and the position of soil
policy in his approval of the present approach.
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5.3.4 A comparison
Table 5.5 and 5.6 give an overview of the substance specific formulas developed to
calculate the reference values and the resulting values for standard soil. The formu-
las used to calculate reference values in the final version are in some cases equal to
previous versions (Cr, Ni, Zn), but in other cases, they are adaptations of the pre- 121
vious versions. A comparison of the concentrations for the metals in more extreme
chapter 5
soil types like sand, clay and peat is given in Table 5.6, and reveals these differences.
Table 5.6 Reference values for standard soil. For the provisional reference values (column 2) standard soil is
defined as soil for which the mass percentage of lutum + 3 times the mass percentage of OM equals 27. For
the alternative approach and the definite reference values (columns 3 and 4), standard soil is defined as soil
with a mass percentage of lutum of 25 and a mass percentage of organic matter of 10. The figures in the 3 rd
column (alternative approach developed by PTCSP) are calculated with the formulas for peaty soil given in
this alternative approach (see Table 5.5).
Ni 50 40 35
Cu 30 30 36
Pb 100 65 85
As 30 20 29
The differences between the values for standard soil are slight as can be read from
Table 5.6. Apparently, for standard soil, the different approaches lead to compara-
ble concentrations. A comparison of the concentrations for the metals in more
extreme soil types like sand, clay and peat reveals the differences between the
approaches (see Table 5.7). In Table 5.7 the column ‘standard soil’ is repeated from
Table 5.6. The columns ‘sand’, ‘clay’, ‘peat’, concentration values are calculated
above which the criterion for multifunctional soil quality is exceeded. For most sub-
stances, the more organic matter, the higher (i.e. less strict) the standards are.
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Table 5.7 Calculated concentrations for metals for standard soil, sand, clay and peat adapted from (VTCB 1986 p. 26). The
characteristics of these soil types are defined in PTCSP 1986 (VTCB 1986 p.19). *For the first and third column, standard
soil has a C value of 27; in the second column, standard soil has a C value of 25. Concentration in mg per kg.
Ni 50 40 35 17 21 33 67 64 67 170 43 13
Cu 30 30 36 10 16 19.8 40 48 52 100 32 52
Zn 180 120 140 62 60 66.5 240 192 228 600 129 148
Cd 1.0 0.8 0.8 0.3 0.3 0.5 1.2 1.0 0.9 3 0.9 1.7
Hg 0.30 0.2 0.3 0.1 0.1 0.4 0.4 0.3 0.4 1 0.2 0.3
As 30 20 29 10 10 18 40 32 40 100 22 40
These figures illustrate that the differences between the three stages of development
of the reference values become visible only when looking at different soil types. The
main difference between the respective versions is in the classification of soil types.
The development of the reference values affected the context of standards for soil
quality. The impact of the labelling of usable knowledge and the establishment of the
reference values are regulative, cognitive as well as normative. In the regulative dimen-
sion the reference values introduced effect-oriented assessments and created meaning
to the role of standards in soil protection and pollution policy. Cognitively, the refer-
ence values gave meaning to the principle of multifunctionality and affected the
research agenda. In addition, through the development process of the reference val-
ues, the relations between science and policy in such technically complex matters were
established, as well as the relation between the different ministries and policy fields.
sons for developing standards was the awareness that there are ‘Limits to growth’ and
in the document there were ample references to the international report by the Club
of Rome (Meadows 1972) as well as to the UN conference in Stockholm (1972).
Standards are perceived as instruments that provide a frame, within which economical, technical
and social processes can develop. 123
(Min.V&M 1972 p. 46)
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Most prominent in the Priority Memorandum was the motivation for setting envi-
ronmental quality standards. This motivation is abstract. Further reference to the
role of standards in policy development and implementation is scarce and not very
specific, as the above quote illustrates. In 1976, a second seminal policy document
was published: Memorandum Environmental Health Standards (Min.V&M 1976).
The aim of this document was to summarise the current line of thinking about
quantitative standards, and to explore the possible roles of standards in environ-
mental policy. However, the document did not produce anything other than a list
of different types of standards: emission, immission, process and product standards
and an exposé about the importance and relevance of such categorisation.
From the above, a picture emerges of a newly developed instrument of which the
ultimate consequences during implementation were not yet fully thought out or
worked out beforehand. In the process of developing the reference values concern
over implementation aspects popped up regularly, but were not an explicit subject
of debate. It seems as if that is considered as something that has to be solved in prac-
tice, and should not be discussed openly.
Only after the hurdle of deriving a list with standards was taken, space was cre-
ated to discuss these aspects. This was done prominently at the symposium
‘Environmental Quality’ in December 1986. This symposium was organised by the
PTCSP. Here, Wessels Boer, staff member at the ministry and responsible for stan-
dard setting and substances, tried to analytically unravel the confusion by position-
ing standards along the problem of the life cycle chain (VTCB 1986c). In doing so,
he pulled the standards out of the scientific and technical sphere and positioned
them as instruments in policy processes. The policy process is depicted as consist-
ing of four stages: Problem recognition, Policy formulation, Solution, and
Management. He positioned standards at each of the transitions and called the
respective roles of the standards: problem setting, task setting and management
instruction. After that, he explained that soil policy was at the start of the policy for-
mulation stage. The reference values therefore had a problem-setting role. They
helped to indicate the nature and size of the problem and help to formulate policy.
In the second part of his speech he sketched the future of soil policy and the role of
standards therein and foresaw that reference values would get a more task-setting
role in the following stage of the policy cycle. His stage-wise interpretation of poli-
bw.souren 18-09-2006 15:47 Pagina 124
cy problems was adapted from Winsemius, the then minister responsible for envi-
ronmental policy (Winsemius 1986) whose influential book in which he propagat-
ed a management approach to environmental problems, was about to be published.
The practical need to discuss the role of standards became urgent as it turned out
that the reference values were used by soil treatment engineers. To them, the refer-
124 ence values were target values for soil cleanup. Within the ministry there was con-
cern about this task-setting use of the reference values.
Reference values for soil quality
After a few years of experience with the reference values, several publications
addressed the confusion about the role of reference values (CRMH 1987, 1991;
TCB 1990). TCSP’s annual report (1990) addressed the fact that policy principles
can be interpreted in a hierarchical order from concrete to abstract. At the highest
level, policy principles are ethical, referring to a deeply rooted notion. At the inter-
mediate, strategic, level principles translate the ethical principles to guidelines for
policy on a specific issue. Finally, there is the operational level, with policy princi-
ples for concrete policy actions, programmes or projects. The principle underlying
the reference values, multifunctionality, is a strategic principle, more than that it is
an operational principle. This issue is intimately related to Section 5.4.2.
chapter 5
sional reference values, although one of the aspects in the letter by the minister
requesting its advice created room for taking this into account:
The advice would have to deal primarily with the following aspects:
…
-the height of the provisional reference values, in relation to their goal, namely the provisional
and partial specification of a multifunctional soil quality, and within the restrictions as given in
the Discussion Memorandum.
(VTCB 1986a)
The PTCSP addressed this aspect and identified inconsistencies in the definition of
the principle of multifunctionality as provided in a sequence of policy documents.
5.4.3 Interactions between science and policy over complex technical issues.
In 1985, the initiative to develop standards was taken by policy. At that time, and
given the context in which there was a large sense of urgency to proceed with devel-
oping soil policy, policymakers took the initiative for the formulation of standards
and proposed to have them reviewed by the scientists. This was the reason for the
main writer of the Discussion Memorandum on Soil Quality to develop the provi-
sional reference values. The scientific community at Wageningen University scepti-
cally welcomed the energetic action taken by the ministry:
The rumour spread throughout Wageningen that there was a policy document being produced
containing reference values…
The scientific community felt surpassed, and was highly motivated to provide a crit-
ical review of the provisional reference values through the PTCSP. One of the sci-
entists involved argued:
were times that the minister responsible for the Environment had to answer ques-
tions about a range of aspects related to polluted soils every day. To be able to pro-
vide him with convincing arguments, it was necessary to avail of a ‘coalition’ that
could provide the required information. However, at the same time, the ‘sense of
urgency’ among policymakers to speed up the progress of developing soil policy
made them decide not to wait for scientists to come up with a proposal for stan-
dards, because it would take far too long. The alternative was to take the initiative
and organise a discussion about proposed values. As one of the then policy staff
members stated in the interview:
There was a lot of discussion about the details. Fine, but ultimately we had our standards!
(Interview quote policy staff member at the time)
Through the definition of multifunctionality, soil policy was related to water and
agricultural policies. In these policy fields, quality standards had been formulated as
bw.souren 18-09-2006 15:47 Pagina 127
well. In agriculture, the LAC standards13 related the presence of substances in agri-
cultural fields to residues on crops. Any proposed set of standards for soil quality
had to be compatible with these standards to assure coherent environmental policy.
The reluctance of the other ministries to develop an overarching soil protection pol-
icy (see Chapter 4) made it difficult for the staff members who were preparing the
Discussion Memorandum on Soil Quality to fine-tune the provisional reference val- 127
ues with, for instance, the LAC standards. The staff member stated in his interview:
chapter 5
Through informal talks and phone calls I got the impression that we were not beyond the LAC
standards, and that was interpreted as support for the provisional reference values.
(Interview quote policy staff member at the time)
Chapter 1 introduced the objectives of this research and provided some theoretical
background on standards as instruments. The literature discussed in Chapter 1
makes it clear that standards classify and simplify. This is illustrated in Figure 5.1
below, which explains what reference values ‘do’ to soil quality. Reference values
classify soil into ‘clean’ and ‘polluted’.
13 LAC standards are standards developed by the Agricultural Advisory Committee on Environmental
Contaminants (Landbouwadviescommissie Milieukritische Stoffen). These standards indicate concentration levels
of residues on agricultural products
bw.souren 18-09-2006 15:47 Pagina 128
128
Reference values for soil quality
Reference values
5.5 Conclusions
In Chapter 3, research questions 2 and 3 were formulated for the case studies.
In this section the research questions are answered. The (disciplinary) background
type of knowledge that is labelled as usable is described. Also the relation between
the arguments applied in labelling and the institutional context is given.
Labelling of usable knowledge for the development of the reference values was a
matter of justifying the adequacy of available knowledge to develop reference values
and to satisfy the need for standards to assess soil quality. This first case study
revealed the concerns from policymakers and scientists with regard to the produc-
tion of standards for environmental quality. Policymakers were primarily concerned
with the progress of soil policy, and at the same time suggested that the rationality
of policy was guaranteed. The effort taken to connect the available knowledge to the
principle of multifunctionality illustrates the importance attributed to scientific
knowledge. Clearly, if this was considered less important, government could have
referred to the available knowledge as indicative of the reasonability of the provi-
sional reference values. Instead, government opted to have scientific knowledge
bw.souren 18-09-2006 15:47 Pagina 129
indicating the rationality of soil policy. This opening was given for instance in the
advice by the VCRMH in 1977 (VCRMH 1977). The VCRMH argued in its
advice on the Priority Memorandum on Environmental Health Standards, that as
the development of scientific knowledge trailed behind, standards for environmen-
tal quality should be based on available scientific knowledge.
The scientists’ concern was about the rigor and exactness of the calculation of 129
the numbers, and about their image as experts on ‘getting it right’. In fact, the cal-
chapter 5
culation of reference values was about establishing a soil typology based on lutum
and organic matter content, whereas they were proposed to be about establishing a
typology related to the effects of substances. The arguments applied in labelling all
relate to the sense of urgency to move on with the development and implementa-
tion of soil policy as formulated in the Soil Protection Act (provisionally formulat-
ed in the Preliminary Soil Policy Plan). The strengthening of the regulative dimen-
sion of soil policy was used as an argument to label the Edelman data as usable for
the development of the reference values
The arguments for labelling the available knowledge as usable knowledge in this
case hardly concerned the adequacy of the proposed reference values as instruments
indicating the boundary of good soil quality. The question what type of knowledge
was required to translate multifunctionality was posed and answered in the appen-
dices of the PTCSP report. The initial question by the ministry, asking for advice
about the proposed reference values was not that broad, which was understandable,
as the ministry was in a hurry. A considerable portion of PTCSP report sketched
the contours of the type of knowledge required to formulate standards for effect-ori-
ented policy. However, this body of knowledge was still incomplete and fragment-
ed. The available knowledge and this policy wish (to avail of standards to assess soil
quality) had to be matched.
Related to this first case study, research question 2 (What knowledge is labelled
as usable knowledge?) can be answered as follows: the available knowledge was a set
of raw, uninterpreted data. The data concerned measurements of concentrations of
substances in relatively undisturbed areas. In addition to these data, an approach
was developed and used to calculate reference values. This approach was based on
chemical and physical knowledge concerning abiotic characteristics (lutum and
organic matter content) of soil.
Research question 3 (What are the arguments applied in labelling and how do
they relate to the dimensions of the institutional context?) requires a more extensive
answer. In the argumentation the regulative dimension is referred to explicitly. The
need to develop standards is based on the conviction that these standards are
required to confirm the position of soil policy and explicit reference is made to the
Soil Protection Act. The reference to the cognitive dimension is less explicit. First,
the principle was not yet specified in more detail. Second, the available knowledge
did not relate to the principle clearly; the dataset gave no proof of the presence or
bw.souren 18-09-2006 15:47 Pagina 130
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The maximal tolerable level is reached when the concentration of a substance equals the calculat-
ed concentration at which 95% of all species in an ecosystem is protected.
(Min.VROM 1989b)
Providing the scientific underpinning of the risk approach was the challenge to sci-
entists in this second case study. Between 1987 and 1992 a series of scientific papers
appeared on approaches to assess the fraction of species affected by the exposure to
substances and on approaches to assess the effects on ecosystems. The 95% level
used in the above definition is derived from this work. In 1989, the Health Council
reviewed a selection of these models and advised on the method to be used to cal-
culate standards (Gezondheidsraad 1989). In 1991, target values, for heavy metals
were published (Min.VROM 1991). In 1994, the first set of intervention values was
published for a limited set of substances, including heavy metals (Min.VROM
1994) The case studied in this chapter is demarcated in time, starting with the pub-
lication of the risk approach in 1989 and ending with the publication of the first set
of intervention values in 1994.
bw.souren 18-09-2006 15:47 Pagina 133
In the theoretical chapter it was argued that the arguments applied in labelling usable
knowledge are connected to the institutional context. As we will see in this chapter, the
arguments used to label a specific model to derive target and intervention values can
indeed be related to the institutional context as they are described in the second episode 133
in Chapter 4. In this section the major finds from that chapter are brought together.
chapter 6
The second episode (1989-1994) could be characterised by reflection and renewal.
During the second episode, extensive reflection took place on the first episode. The sci-
entific basis for the reference values was criticised as well as the progress in soil policy
in particular, the treatment of polluted sites. The renewal applies to the introduction of
the risk approach as a new policy principle. The risk approach pertained to the notion
that environmental effects are inevitable, to a certain level (see Chapter 4 for further
explanation). The risk approach further brought about a harmonisation of policy for
the environmental compartments, soil, water and air. Notably in the second episode,
the relation between science and policy on standards for soil quality intensified. The
groundwork was laid in the previous episode and consolidated in this second episode.
Illustrative of the consolidation is that the Provisional Technical Committee on Soil
Protection (PTCSP) was liberated of its Provisional status. Also, a large research pro-
gramme, the Netherlands Integrated Soil Research Programme (SPBO) was established
to develop basic knowledge on soils and the large policy programme for the develop-
ment of Integrated Environmental Standards became operational. This policy pro-
gramme involved a research project conducted at the National Institute for Public
Health and the Environment (the RIVM). With the integration of the Soil Protection
Act and the Interim Soil Pollution Act, the consolidation of soil policy within envi-
ronmental policy became visible.
Table 6.1 The three dimensions of the institutional context in the second episode as described in Chapter 4.
Critical events, achievements and developments are given for each dimension.
Regulative • Integration of Interim Soil Pollution Act and Soil Protection Act
(1994)
Cognitive • Risk approach
• Multifunctionality
Normative • Active soil management
• Increase in number of actors involved in policy development
(notably the VNG, the IPO)
• Integration of environmental policy fields
• Criticism with regard to abstract and insufficiently operational
principles guiding soil policy
• Soil research programme (Netherlands Integrated Soil Research
Programme SPBO)
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With the publication of the risk approach, environmental policy became explicitly
effect-oriented. The maximum and negligible risk levels referred to effects on
ecosystems. Crucial was the protection of ecosystems against adverse effects of sub-
134 stances. The development of standards for effect-oriented policy challenged science
to develop insight in the complexity of ecosystems and in the mechanisms produc-
Target and intervention values
ing effects. In addition, science was challenged to establish the maximum and neg-
ligible risk levels for substances. This required a completely different approach as
compared to the work done to establish the reference values (previous case). Where
the scientific knowledge used in the previous case to derive reference standards was
restricted to physico-chemical knowledge, the second stage in the development of
standards required more ecological knowledge. And ecologists were eager to bring
in their expertise, as can be read from the following quote.
A number of functions are distinguished in the new draft Soil Protection Act, of which the eco-
logical function is designated as the main one. In addition, the term soil quality takes up a cen-
tral position. In this light, it is merely logical to use ecological parameters in the development of
soil quality standards.
(Denneman et al. 1985)
The paper by Denneman and co-authors was one of the appendices of PTCSP’s
advice on the reference values (VTCB 1986b). The contours of an ecological
approach to establish risk levels were sketched in that advice. The appendix was writ-
ten by ecologists and ecotoxicologists from the Animal Ecology group at Free
University (Vrije Universiteit) in Amsterdam then chaired by Mrs. prof. Joosse. To
understand the increased importance of ecological knowledge it is relevant to look at
the principle of multifunctionality and the distinction of the different functions. In
the explanatory statement to the Soil Protection Act it was concluded that the eco-
logical function is the most vulnerable. Hence, protecting the ecological function was
regarded as the most effective way to protect all functions. The assumption was that
the functioning of ecosystems is not seriously affected as long as the structure of the
ecosystem is not seriously (i.e. irreversibly) affected (Denneman and Van Gestel 1990
p. 6). That study by Denneman and Van Gestel provided the background for the
development of the target values. The line of reasoning started from the notion that
the ecological function of soil is determined by soil ecosystems. This implies that seri-
ous risks to the ecological function are serious risks to the soil ecosystem. This line of
reasoning draws heavily on the ecological paradigm that structure, function and their
interrelation characterise ecosystems. This reasoning was backed by referring to the
seminal work of Odum (1971), an influential ecologist in the 1970s. In turn, a seri-
ous effect on the structure of the ecosystem is interpreted as a serious effect on the
bw.souren 18-09-2006 15:47 Pagina 135
species composition. In Figure 6.1, the line of reasoning is summarised. This figure
was already used in Chapter 4 to explain the background of the scientific effort in the
second episode .The prevailing idea (notably within the Animal Ecology group) was
that the crucial ecological function of the soil ecosystem was decomposition; the
process in which organic material is degraded (fragmented), nutrients are mineralised,
and then humus (soil organic matter) is formed. Through decomposition, the cycle of 135
carbon, nitrogen and other organic nutrients is closed. The process of fragmentation
chapter 6
of organic material received most attention, in part because that was the expertise of
the group that conducted research with soil fauna, active in the first part of the
decomposition process. Through toxicity tests with soil organisms it could be assessed
under what concentration the ecological function would be adversely effected (Van
Straalen pers.comm).
Figure 6.1 Operationalisation of ‘Serious risk to functional characteristics of soil’ (Denneman and Van Gestel
1990 p. 7).
This line of reasoning underlies the scientific work done in this episode. Toxicity
tests on soil organisms were conducted, starting with tests on individual organisms
and using the results as input to model the dose-response relation. As explained at
the start of the chapter, the challenge for science in this case was to model the com-
plex ecosystem and to deal with the methodological uncertainties typical for such
undertakings.
There are at least three uncertainties in developing a scientific method: ecologi-
cal complexity, experimental setup, and modelling/statistical assumptions. The eco-
logical complexity relates to the complexity of ecosystems and their effects to expo-
sure. Ecosystems are characterised by interactions between individual organisms and
their biotic and abiotic environment. Establishing the vulnerability of a species to a
certain substance requires an understanding of the ecology of the species, but also
of the biophysical mechanism causing the effect of the specific substance in that
bw.souren 18-09-2006 15:47 Pagina 136
imental conditions, and this was one of the tasks set for the Netherlands Integrated
Soil Research Programme (SPBO, see Chapter 4, episodes 1 and 2 for more back-
ground). Examples of experimental conditions that required standardisation are: dura-
tion of exposure, selection of test species, standardisation of soil used in experiments
and food. In modelling multiple species systems, numerous assumptions had to be
made to assess the effects of substances on such systems. Accordingly, different mod-
els were developed, each with different assumptions and different data input. The
main models are discussed and their assumptions are explained. The labelling of
usable knowledge in this case centred on the assumptions in these models used to
determine the maximum tolerable level. The modelling consisted of two steps. First,
the effects on a single species were modelled, and specific concentration levels were
determined. Second, these concentration levels were used as input for multiple species
models. In the following two sections these two steps are explained.
In the first step, data from single species toxicity tests are collected and modelled.
In experiments, individuals of a test species (well known are springtails and earth-
worms) are exposed to soils, spiked with known concentrations of a certain sub-
stance. In a series of experiments, the animals are exposed to a range of concentra-
tions in an experimental setup consisting of several replicates and controls. Exposure
time is kept constant (i.e., standard exposure for earthworms is two weeks). Several
endpoints can be measures, but mortality, growth and reproduction are mostly
used. The measurements are related to the exposure concentrations and through
regression analysis, a relation between concentrations and, for instance, survival is
determined. The resulting models produce graphs like Figure 6.2 below.
On the X axis the logarithm of the concentration of a substance is plotted. The
response is on the Y axis. The graph shows the relation between effect (for instance,
mortality) and concentration under the specific exposure time and climatic condi-
tions. The shape of the curve above is typical for xenobiotic substances, i.e., those sub-
stances that are not naturally occurring in the body. Essential substances are required
in certain concentrations for essential processes. Concentrations of these substances
that are below as well as above a certain level have an adverse effect. Dose-response
bw.souren 18-09-2006 15:47 Pagina 137
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curves.
relations for essential substances thus are typically bell shaped, and have an optimum
range of concentrations. Drawing dose-response curves requires data derived from
replicated experiments under controlled conditions in the laboratory. Given the vari-
ation in experimental data (for instance, due to individual variation between organ-
isms) and the restricted number of data (due to practical delimitations) these curves
are drawn using statistical extrapolation techniques. Analytical statistical techniques
are applied to determine the Lowest-Observed-Adverse-Effect Level (LOAEL) or No-
Observed-Adverse-Effect-Level (NOAEL). Due to experimental errors and natural
variation between organisms, there is always a variation in the data, as indicated in
Figure 6.3 by the vertical lines, which represent the standard deviation. The NOAEL
is the highest dose on the X axis at which no significant deviation from the 0%
response is observed. The LOAEL indicates the lowest level, significantly different
from the control level, at which no adverse affects were observed.
Figure 6.3 Typical dose response curve, with LOAEL and NOAEL as examples of characteristic dose levels.
The vertical error bar of the LOAEL overlaps with the error bar of the NOAEL.
bw.souren 18-09-2006 15:47 Pagina 138
in more detail in Section 6.2.2. The second concentration level that can be calcu-
lated from these single species dose-response relations is the NOEC (No-Observed-
Effect-Concentration), the highest concentration level at which no significant devi-
ation from 0% effect occurred) for species occurred. The NOEC was used by Van
Straalen in his model, that will also be discussed at more length in Section 6.2.2.
The NOEC (like the EC50) is specific not only for species, substance and climatic
conditions but also for exposure time. Clearly, chronic exposure to a concentration
will eventually have more effects than a short (acute) exposure to the same concen-
tration. Although it is generally acknowledged that chronic exposure is more realis-
tic, experimental setups are designed preferably for acute toxicity tests. Statistical
procedures have been developed to relate acute NOEC to chronic NOEC levels.
After having calculated these chronic NOEC levels, NOECs are used to asses the
effect of substances on sets of species in Species sensitivity distributions (SSDs).
Initially, these models were called ‘extrapolation models’ In a review of these mod-
els (Posthuma et al. 2002), they were called ‘species sensitivity distributions’ (SSD).
That name and acronym are used throughout this thesis.
An SSD is a statistical distribution describing the variation among a set of species in toxicity of a
certain compound or mixture. The species set may be composed of a species from a specific
taxon, a selected species assemblage, or a natural community.
…
It may be assumed that by protecting most of the species with a conservative cut-off value, the
associated percentile (concentration) is also protective of ecosystem properties, but that assump-
tion remains to be validated.
(Posthuma et al. 2002)
bw.souren 18-09-2006 15:47 Pagina 139
Species Sensitivity Distributions are constructed by plotting NOECs from the pre-
vious modelling step (after a log-logistic transformation) on the X axis. The num-
ber of species for each NOEC is plotted on the Y axis. Assuming a log-logistic nor-
mal distribution, a curve is plotted through these data.
139
chapter 6
Figure 6.4 Typical species sensitivity distribution. The log NOECs from the tested species are on the X axis.
The fraction of species with the corresponding NOEC level is on the Y axis. The mean of the distribution HC50
(or mean NOEC) is used to derive intervention values (Section 6.4.2). The HC5 is the lower level of the 95%
confidence interval for the log concentration above which 95% of the species is exposed to lower levels than
their NOEC. This HC5 is used to derive target values.
tality rate to population growth rate) these models conceal knowledge or assump-
tions about the expected effects of substances. Given the fundamental lack of data,
assumptions about the toxic mechanisms and about the sensitivity of species or tax-
onomic groups are at the heart of these models. Describing the assumptions, mak-
ing them as robust and trustworthy as possible, is one of the crucial aspects of a
140 model. With all models, the assumptions in the SSDs are the Achilles heel. Now
that there is a distribution of species sensitivity, the issue is where to set the level of
Target and intervention values
acceptable risks. The answer is stunningly simple and in sharp contrast to all scien-
tific calculations, extrapolations and modelling done so far. In fact, there was no
solid scientific argumentation to set such a level.
At that time I, I am a bit pragmatic… You have to answer the question in a different way. An
answer that is not only fundamentally right, but it also has to be palatable; it has to produce a
usable result. The only thing I could think of was that 5% fraction.
(Interview quote, author of the Van Straalen method)
Having explained the general characteristics of these SSDs the alternative models
that were developed, and evaluated by the Health Council, are explained. The two
main models: Kooijman and Van Straalen, are explained with a focus on their dif-
ferences. These models were evaluated by the Health Council in 198815 to be used
to calculate the concentrations levels that served as input in the development of
standards used in soil policy.
Kooijman (1987)
The first attempt to provide policy with an approach to assess the risks for ecosys-
tems was te approach developed by Kooijman (1987). Kooijman was working as a
theoretical ecologist at the Free University in Amsterdam when he published his
model, but started work on this extrapolation model earlier while working at TNO
in government-funded projects (Kooijman 1985a). Kooijman was concerned with
the protection of the most sensitive species, more than with the protection of a fixed
set of species (like 95%). Kooijman developed his model to deal with the enormous
differences in sensitivity between species (Gezondheidsraad 1988). Kooijman was
motivated to increase the awareness amongst researchers and policymakers that
extrapolations beyond the limits of knowledge required the application of safety fac-
tors. Implicit in this motivation was his plea to fund more ecological research to
increase the experimental database, and to provide more reliable estimates of con-
centration levels (Kooijman pers. comm).
15 In addition, models were developed by the Environmental Protection Agency (EPA 1984) and by Blanck (1984)
bw.souren 18-09-2006 15:47 Pagina 141
chapter 6
chronic exposure is used, but for practical reasons acute exposure is applied, and sta-
tistically translated into chronic LC50 values. This safety factor depended on the
number of test species and increased with the size of the community (larger com-
munities are more likely to include sensitive species, as assumed by Kooijman). It
also depended on the variation in LC50 values, and on a coefficient determining the
probability that the proposed safe concentration is larger than the LC50 of the most
sensitive species. The HCS can be regarded as a lower boundary for concentrations
that can be expected to be harmful for a given community. The HCS has been cho-
sen so that the LC50 value of the most sensitive species in a community of a cer-
tain number of species exceeds that concentration by a specified probability
(Kooijman 1987). Typical about this method is that the HCS depends on the num-
ber of test species and on the number of species in the community. Kooijman
assumed that LC50 values of community species and test species have a log-logistic
distribution. Kooijman did not select his test species for their ecological function,
taxonomic group or other ecological criteria. He assumed that those characteristics
were not determinant for the distribution of sensitivity, and therefore not important
to consider. By the time he developed the first versions of his model no decisive
research was available on this issue.
toxic substances (Van Straalen and Denneman 1989). These ecological criteria were
not applied by Kooijman; he doubted the ecological grounds for differences in sen-
sitivity at the time. As a third contrast to the model by Kooijman, these authors
chose not to calculate a hazardous concentration for the most sensitive species. They
followed another line of reasoning. They calculated the HCp, the hazardous con-
142 centration for p% of the species, with p as a relatively small number. In their origi-
nal publication the authors used a p value of 5. In other words, in the SSD in Figure
Target and intervention values
6.4 above they calculated the concentration level that corresponds with the 5%
interval of the most vulnerable species. This approach produced different concen-
tration levels indicative of the protection of a multiple species ecosystem. In most
cases the model by Kooijman produced a lower Hazardous Concentration (HC)
level (but one that depended on the number of test species and the number of
species present in the community). Figure 6.4 below compares the two methods.
Figure 6.4 The difference between the HCS model (Kooijman) on the left, and the HC5 model (Van Straalen)
on the right.
In this figure, the three distributions display the differences between the two mod-
els with respect to the statistical/mathematical choices. Internationally, the develop-
ment of ecotoxicological experimentation also continued, notably in Denmark
(Wagner and Løkke 1991) and the US (Blanck 1984; EPA 1984). The setup of
experiments to develop dose-response relations within species as well as assessments
of effects on ecosystems (multiple species and their interactions) were the focus of
bw.souren 18-09-2006 15:47 Pagina 143
ecotoxicology as a scientific field in the 1980s and 1990s. In 1992, the approach
applied in the Netherlands was approved by the OECD (1992) to serve as the
European model (Van Straalen and Van Leeuwen 2000). The models differed in
their selection of test species.
143
6.3 Labelling usable knowledge
chapter 6
The contours of an approach to model multiple species systems and calculate risk
levels was sketched in 1985 as an appendix to the PTCSP”s advice on the reference
values (discussed extensively in Chapter 5 (Denneman et al. 1985). Through the
publication in this advice, part of the labelling of usable knowledge was done. By
publishing the appendix, the PTCSP helped to launch this ecological approach in
effect-oriented environmental policy, and, being a significant advisory committee to
the ministry, its commitment was effective. The authors of the ecological approach
in PTCSP’s advice not only brought forward their knowledge and expertise on
effects of substances and how to assess these, they also explicitly connected this
expertise to a significant policy problem as illustrated by the quote in Section 6.2.
The ecological approach was further refined and fleshed out through research proj-
ects under the flag of SPBO and the Project Integrated Standard Setting.
An important second step in the labelling of usable knowledge for the develop-
ment of standards for soil quality was the Health Council’s advice on the
Ecotoxicological Risk Assessment of Substances (Gezondheidsraad 1988). In
December 1987, the Minister of Housing, Spatial Planning and the Environment
asked the Health Council to provide an advice on the extrapolation methods best
suitable for risk assessment (and to be used in the Scoping Documents16). The
Health Council was asked to evaluate a report prepared by an Interdepartmental
Working Group on Risk Management of Ecosystems. It is important here to note
that the Health Council is now actively involved in this second case, whereas its role
was limited in the previous case study. The reason for this is that the Health Council
had meanwhile expanded its scope, to include Environmental Health next to Public
Health issues (see (Bal et al. 2002) for a description and analysis of the role of the
Health Council in scientific advisory).
This working group proposed the minimal requirements for scientific data to be
included in the Scoping Documents for substances. This proposal contained a dif-
ferentiated procedure for risk assessment for different environmental compartments
(water, air and soil). For soil, the working group proposed the following procedure:
16 A scoping document provides the basic information of a substance, including its toxicity and is used as input
for the development of standards. It is prepared by the RIVM (also see Figure 1.3a).
bw.souren 18-09-2006 15:47 Pagina 144
A minimal requirement are results of acute toxicity tests with plants, earthworms, and soil
arthropods (according to OECD Testguidelines).
In case LC50 /exposure concentration is > 100, values can be calculated applying the methods
by Kooijman (1985, 198)7 and Van Straalen (1987).
In case LC50 /exposure concentration is < 100, chronic tests need to be executed with the
144 above-mentioned test species. With the results of these experiments, concentration levels need to
be calculated with the above methods.
Target and intervention values
The working group was not explicit in its choice for the models to be used by put-
ting both models between brackets. The Minister of Housing, Spatial Planning and
the Environment’s request (December 29, 1987) contained the following:
…an evaluation of the proposed procedure, an assessment of the protection level of ecosystems
following this proposed procedure, its applicability and the gaps in the procedure.
The letter further invited the committee to propose directions to fill the gap and to
bring in new approaches that existed but were not mentioned by the Working
Group. In the letter it was made clear that the existence of other approaches should
only be signaled, but should remain outside the evaluation. In other words, the
committee should restrict its evaluation to the models mentioned in the proposed
procedure by the Working Group (Gezondheidsraad 1988 pp.19-20). With this
restriction, the letter explicitly labels usable knowledge by excluding alternative
models from the advice. The models developed by EPA and by Blanck (mentioned
above), were not to be included in the advice. Although I did not track the argu-
mentation for this selection made by the Minister in his request for advice, it could
be suggested that the selection of models exclusively from Dutch origin has been a
strategic choice. The Minister can steer the development of such models in the
Netherlands by allocating funds, but this is not so easily done internationally. In
addition, as was shown in Chapter 4 (first episode) the creation of a coalition
between science and policy was considered important. Clearly, it would be easier for
the ministry to develop and maintain such a coalition with national, Dutch scien-
tists than with an international scientific community.
The Health Council Committee, installed in January 1988 to write the advice,
consisted of ecologists and ecotoxicologists. Amongst the members were the two
authors of the extrapolation methods (Kooijman and Van Straalen). The committee
took the freedom to give its own interpretation to its task and proceeded with draw-
ing up an overview of the state of the art in ecotoxicology, thus evaluating the scien-
tific quality of the proposed procedure. This assessment then was followed by an eval-
uation of the relation between the proposed procedure and Dutch policy for the pro-
tection of ecosystems. The first statement by the committee is that insufficient scien-
bw.souren 18-09-2006 15:47 Pagina 145
tific knowledge is available on the structure and functions of ecosystems and conse-
quently that further research must be carried out, fundamental as well as applied
(Gezondheidsraad 1988 p 25}. Such statements are obligatory for such committees, it
seems. However, they become a nuisance when these statements are not more precise
about the ways to acquire such insight. The committee concludes that
145
…the procedure to be assessed is meant to judge the effects of substances on ecosystems based
chapter 6
on the current, limited ecotoxicological knowledge.
(Gezondheidsraad 1988 p. 26)
and further:
The committee states that a protective strategy, based on such a small theoretical basis (i.e., the
relation between structure and the functioning of ecosystems) is on several points contestable.
(Gezondheidsraad 1988 p. 26)
According to the committee, there was no sound scientific reason to contend that
the procedure as proposed by the Working Group would produce concentration
levels at which the ecosystem would indeed be protected. The scientific basis was
considered to be too small. According to the committee, the procedure proposed by
the Working Group reflected the current state of scientific knowledge. The com-
mittee then reformulated the request for advice:
1) The assumptions and applicability of the procedure, the prerequisites for experimental
results, the selection of the extrapolation method.
2) The selection of test species and tests.
3) The extrapolation methods in the procedure, including a comparison with other available
methods.
(Gezondheidsraad 1988 p. 27)
In doing so, the committee restricted the span of the advice to the scientific aspects
of the proposed procedure. The committee wanted to refrain from the suggestion
that it would qualify either of the models as appropriate (i.e. perform labelling of
usable knowledge). In the advice the committee compared the two models. In this
comparison, only scientific criteria (experimental conditions, choice of parameters,
and the size of the sampled population) were included. Below are some examples to
illustrate the scientific character of the comparison.
The Kooijman model does not take into account the relations between species and is exclusively
based on results from laboratory experiments. Under field conditions, the fraction of the sub-
stance that is available to species is lower.
(Gezondheidsraad 1988 p.37)
bw.souren 18-09-2006 15:47 Pagina 146
The assumption in the Van Straalen method that an ecosystem is protected if only 5% of the
species is exposed to concentrations above their NOAEL [See Section 6.2.1 for an explanation
of this term, AS] is not scientifically grounded.
(Gezondheidsraad p. 39)
146 The assumption of a log-logistic distribution in both models is contestable. The results from the
Van Straalen method are less determined by the shape of the distribution at the upper and lower
Target and intervention values
So far, the committee concludes, there were no scientific grounds to prioritise one
method over the other. In search for grounds to distinguish between the methods,
the committee broke down the methods to two basic aspects: the principle of the
methods and the approach of the methods, and investigated whether these two
aspects could provide grounds for differentiation or not. The principle of the method
by Van Straalen was considered problematic if a combination of substances had to be
evaluated. The committee argued that it is most likely that for each substance a dif-
ferent 5% of the species is exposed above their NOAEL, whereas in the Kooijman
model the chances of the most sensitive species being exposed to a concentration per
substance can be calculated. A second difference was that the method by Kooijman
always produced lower concentration levels (i.e., it is more strict). The outcome of
this analysis by the committee did not alter the previous conclusion: both models
cannot pretend to produce concentration levels that protect the ecosystem.
In its advice, the committee proceeded the investigation by applying datasets for
two substances (Cd and γ-HCH) to both methods and compared the outcomes and
reached two conclusions: Firstly, the outcome produced with the model by
Kooijman depends significantly on the size and quality (in terms of the variation
between the LC50s or NOECS values) of the available dataset. This variation could
produce differences up to a factor 10 in the resulting HCS. The fact that experi-
mental conditions caused such variation in the outcome of the model was counter
to the principle that the outcome of extrapolation methods would depend mainly
on the variation between species, the committee concluded. The calculated con-
centrations by the Kooijman method were determined to a large extent by experi-
mental differences, rather than by actual differences between species. Secondly, the
outcome of the Van Straalen method produced concentration levels that resembled
the concentrations calculated from available NOEC data from a large dataset on
aquatic NOECs. In other words, the outcomes of the Van Straalen method were
supported by empirical data. This validation of the Van Staalen method was deemed
important by the committee. This was used by the committee as a reason to prefer
the Van Straalen method.
In this part of the advice the committee evaluated both models on scientific
bw.souren 18-09-2006 15:47 Pagina 147
grounds. However, the first point (i.e. that the outcomes produced by the Kooijman
method were contingent with experimental conditions) is related to the applicabil-
ity of the method and not to scientific criteria in the strict sense. The problem lies
not in the model itself – Kooijman had always made clear that the parameters in the
model were sensitive to experimental conditions. The problem was rather in the
applicability, or robustness of the model. Indeed, with new and better experimental 147
conditions, the outcome of the model would be different, implying that with new
chapter 6
and better experimental conditions, the calculated concentration levels would
become less strict. Clearly, such an outcome is difficult to maintain in policy: more
and better experiments can result in less stringent risk levels. This part of the advice
exposed the criteria applied by the committee in assessing the different extrapola-
tion models. In the next part of the advice, the committee analysed the proposed
method developed by the Working Group Risk Management Ecosystems. On pp.
68-69 of the advice the committee writes:
The procedure does not explicate what model [Kooijman or Van Straalen] should be used, and
what the status is of the calculated concentration levels. The different steps taken to extrapolate
laboratory to field conditions should be described in more detail, especially as the two models
differ with respect to this.
(Gezondheidsraad pp. 68-69)
The committee then proposed to combine the Kooijman and Van Straalen method.
1) The HCS (Kooijman method) is calculated, based on acute toxicity tests with three standard-
ised tests with δ1 and δ2 at 0.1.17. In case bioavailability is known and the laboratory condi-
tions are known to be very different from field conditions, the outcome of the Kooijman extrap-
olation (HCS) can be adjusted to Uk18
2) In case Uk is below the expected exposure concentration, chronic toxicity data are needed (see
step 3). If not Uk is the outcome of the procedure, otherwise step 3 applies.
3) Based on chronic toxicity experiments conducted with ecologically representative test species,
with δ1 and δ2 at 0.05. 19, the Van Straalen method is applied. Also in case lab conditions dif-
fer from field conditions, the outcome is adjusted, resulting in Ust.20. If the ecosystem con-
tained species with a special value (economically, commercially, recreational), the Ust had to be
adjusted so that it equalled the NOAEL of the most sensitive of these species.
17 δ1 and δ2 together determine the probability that the LC50 of the most sensitive species is below the HCS.
18 Uk refers to Uitkomst Kooijman (outcome by Kooijman).
19 See fn. 17
20 Ust refers to Uitkomst Van Straalen (outcome by Van Straalen).
bw.souren 18-09-2006 15:47 Pagina 148
4) The outcome of step 3 needs to be tested for other substances with available datasets.21
(Gezondheidsraad pp. 93-94)
A careful reading of this alternative procedure makes it clear that in most cases the
Van Straalen method has to be applied. After all, the calculated Uk is known to be
148 strict (see the description of the principles and approaches of the methods in
Section 6.2.2). On p. 71 of the advice, the committee advises to set ?1 and ?2 in the
Target and intervention values
21 This deviates from the text in the advice. In the advice, a third model is included. This is an extrapolation
method by Slooff (1987) who worked at THE RIVM. In short, the essence of his method was to apply regression
analysis to the available data. Slooff exclusively used aquatic data. Given this fact, together with the relative lack of
ecological theorising behind the model, the HC committee criticised this approach, but nevertheless included it as
a test for the outcome of the third step.
bw.souren 18-09-2006 15:47 Pagina 149
Van Straalen model tried to match scientific recognition and recognition from pol-
icy. The observed differences between the two models and approaches are typical for
the distinction between research science and regulatory science and pertain to the
relation between science and policy.
149
6.4 Setting the standards
chapter 6
Section 6.3 explained the production and labelling of knowledge applied in setting
standards for soil quality according to the risk approach. The risk approach as such
distinguished two risk levels (The Maximum Tolerable Level (MTL) and the
Negligible Risk Level (NRL) at 1% of the MTL). The use of two risk levels origi-
nated from adjacent policy fields (policy on radiation, large technical installations
and new substances to be put on the market). In environmental policy the approach
was adopted as part of a strategy to harmonise policy fields concerning environ-
mental threats. The exact wording of the risk levels was given in the above defini-
tion and as Section 6.3 showed, these were based on the scientific extrapolation
model developed by Van Straalen.
Besides this (new) framework of risk levels introduced by the risk approach, the
frameworks of ABC values and reference values (Chapter 5) were still used in soil
policy. The scheduled evaluation of the ABC values (a requirement of the legal
framework) provided an opportunity to integrate the existing standards in the new
formulations of soil quality standards and risk levels. The new framework was pub-
lished in full in the policy document MILBOWA. The relation between the exist-
ing and the new framework is as follows: the reference values derived in the previ-
ous episode are updates of the A values. With the introduction of the risk approach
two ‘new’ standards were introduced: target and intervention values. Target values
for substances demarcate clean soil from polluted soil. Target values are the policy
formulation of scientifically derived Negligible Risk Level (NRL). For the
Maximum Tolerable Level (MT), the scientific calculation and modelling was done
by the RIVM and was published in a set of studies that were brought together in
the report Desire for Levels (Van de Meent 1990). The target values thus are set at
1% of the concentration at which 95% of the species are exposed to concentrations
below their NOEC (i.e. the MTL).
Meent, 1990)). It was decided that the target values should never be stricter than
the background values (Van de Meent et al. 1990). In case the calculations would
result in concentration levels below the background values, the target values would
be set at these background values. For all metals, the calculations indeed resulted in
concentration levels below the background values, and consequently the target val-
150 ues were set at these background values. The outcome of the statistical exercise and
the subsequent policy considerations is therefore quite stunning; the target values
Target and intervention values
are exactly the same as the reference values published in 1988 that were regarded to
represent naturally occurring background concentrations (background values).
Target values
Concentrations in mg/kg dry soil
Cr 100
Ni 35
Cu 36
Zn 140
Cd 0.8
Hg 0.3
Pb 85
As 29
The intervention values were developed within the framework of the evaluation of
the C values given in the Interim Act Soil Pollution (see Chapter 4). The evaluation
of the C values would have to result in effect-oriented and scientifically underpinned
standards. The C values, in the new terminology the intervention values, indicate
that soil quality is such that treatment is necessary. Locations where concentration
levels exceed the intervention values are classified as severely polluted which implies
that they have to be further investigated to determine the urgency and the time
schedule for treatment. The height of the intervention values directly determines the
size and number of polluted areas that have to be cleaned in the near future.
The ecotoxicological component of the intervention values represents the con-
centration at which 50% of the species in an ecosystem is affected, i.e. the median
value of the species sensitivity distribution or HC50. The scientific underpinning
for this median value is contested and not explicated. In addition to the calculation
bw.souren 18-09-2006 15:47 Pagina 151
chapter 6
comparison of human toxicological and ecotoxicological assessment. In the last column the C values are listed
for comparison.
Cd 12 12 20
Hg 10 10 10
As 25 55 50
In the previous sections the scientific extrapolation models and the labelling of
usable knowledge are described. This labelling not only facilitated the calculation of
standards, but had a much broader meaning that is elaborated in this section, in
which various impacts of this case on the context for standard setting and soil qual-
ity policy are explained. Most notably, the target and intervention values were oper-
ationalisations of the risk approach.
22 This thesis only addresses the ecotoxicological component of the intervention values. There was a separate track
to assess the effects of substances on human health. The intervention value was set at the lowest of these two fig-
ures. See also: Health Council. 1995. The project Setting Integrated Environmental Quality Objectives. The
Hague: Health Council of the Netherlands.
bw.souren 18-09-2006 15:47 Pagina 152
In the National Environmental Policy Plan in 1989, the policy document ‘Premises
for Risk Management’ was published. In this document the risk approach was out-
lined. Risk had been defined there as:
152
Unwanted effects of certain activities and the probability that these effects occur.
Target and intervention values
(Min.VROM 1989b)
In the document six aims of introducing the risk approach were listed and two of these
are relevant for this thesis. First, the aim of prioritising. By introducing risk levels, pri-
orities could be assigned. Intervention values became the tools to determine the
urgency of locations that have to be treated. The issue of prioritising was important
in soil treatment around that time. During the development of the intervention val-
ues, the Welschen Working Group evaluated the progress of the cleanup operation of
the sites that had been designated as being polluted. This committee’s report was dis-
cussed in Chapter 4 (Werkgroep Bodemsanering 1993). Priority setting of treatment
of polluted sites was supposed to be an adequate answer to the recognised stagnation
of the soil treatment operation, and was mentioned in the report of the working group
as an important step forward. Second, the aim of developing a consistent set of stan-
dards with which it is possible to harmonise standards between the three environ-
mental compartments, soil water and air. Or, in other words, environmental quality
for all three compartments had to be in harmony. The extrapolation models were eval-
uated for this aim in the Health Council advice of 1988. For scientists this aim of the
risk approach enabled the development of intercompartmental harmonisation mod-
els. The extrapolation methods or SSDs became tools to harmonise policy fields next
to the assessment of potential risks to soil ecosystems.
first case study, that the ecological function was not adversely affected in relatively
undisturbed areas. In this second episode the ecological function was more thor-
oughly researched. However, all significant policy and scientific documents in this
second case study state that the knowledge available or developed by that time was
insufficient, but there was agreement that significant steps were being made towards
gaining insight in the ecological function and structure of ecosystems in this 153
episode. This is an important difference with the previous episode. However,
chapter 6
although this ecological function was further fleshed out with the development of
the extrapolation methods, the principle of multifunctionality became subordinate
to the risk approach as a guiding principle in soil policy. Central to the risk
approach was the recognition of adverse effects, and this was counter to the concept
of multifunctionality. As I described in Chapter 4, in the second episode, critical
evaluations of the concept of multifunctionality and of the stagnation of the treat-
ment operation coincided with the introduction of the risk approach. The imme-
diate operationalisation of the risk approach in two Risk Levels and the quantitative
operationalisation of 95% protection level contrasted sharply with the relatively
loose and vague formulation of the principle of multifunctionality.
the research programme SPBO (see Chapter 4, episodes 1 and 2 for an explanation
of the programme), plant sciences were excluded explicitly, as that would increase
the number of participants and consequently would fragment the available
resources for research. These issues, the selection of members in scientific and poli-
cy-related committees concerning regulatory policy and the arguments used in
154 those selection processes would be interesting to study, as already suggested in
Chapter 3.
Target and intervention values
The joint introduction of a new policy concept (the risk approach) and its oper-
ational measures of target and intervention values is interpreted in this chapter as a
successful and effective strategy to institutionalise the effect orientation in soil pol-
icy. Target values are the operationalised expression of the principle of multifunc-
tionality, but above all they are instruments to implement the risk approach. Target
values are problem setting in the sense that they make visible the size of soil pollu-
tion. In addition, target values are the goals of treating polluted soils. Cleanup has
to result in soils that meet the target values, and reduce the area of polluted soil.
Intervention values are a different type of standard. They are task setting. Below the
intervention values, the so-called obligation to make an effort (inspanningsver-
plichting) should be respected. This obligation to make an effort is a normative rule
to maintain the level of pollution and prevent its further increase. Concentrations
above the intervention values have to be treated.
In the publication of their model, the authors of the Van Straalen method explicit-
ly stated their interest to interact with policy. The abstract of the paper refers explic-
itly to the implementation of soil policy, and towards the end of their paper the
authors evaluate the reference values for cadmium and state that the reference val-
ues as determined by the government were in need of adjustment (at least for cad-
mium). The authors further suggest presenting their work in a format such that pol-
icymakers would have to decide themselves about an adequate risk level (Van
Straalen and Denneman 1989 p. 250). Kooijman is explicit about his ambitions in
his paper. With the Health Council’s advice, an important step was taken towards
the development of the two risk levels announced in Premises for Risk Management
in 1989; the Maximum Tolerable Level and the Negligible Risk Level. In Section
6.3 the differences between the two methods in this respect were explained.
bw.souren 18-09-2006 15:47 Pagina 155
Target values indicate the soil quality where the risk of adverse effects for ecosystems and func- 155
tions of soil is negligible.
chapter 6
(Min.VROM 1991)
In a performative role, target values classify soils as either clean or polluted. Target
values are expressed as concentrations of substances that are indicative of a specified
environmental quality. Intervention values distinguish two subclasses within pollut-
ed soil. Above the intervention values soil is severely polluted and has to be treated.
Below the intervention values the pollution is not severe. Further pollution has to
be prevented, but there is no need for a scheduled cleanup. Target and intervention
values classify soil into three categories: ‘Clean’, ‘Not severely polluted soil’, and
‘Severely polluted soil’. Compared to the previous case, the classification has
become more complex in two respects. Firstly, polluted soil has been subdivided
into severely and not severely polluted soil. Secondly, rules of inference have become
much more explicit and articulated. The standards are not only informative about
the physical properties of the soil, but are also informative about the treatment
schedule. The standards are much more performative compared to the previous case
with respect to the treatment of sites.
In addition, the classification of soil has changed, although the concentration
levels of target values and reference values are the same. If we look at Figure 6.5, the
demarcation between clean and polluted is the same as the demarcation between
clean and polluted in the previous case, study, but the meaning of the demarcation
is different. In the previous case, the difference was that soil did or did not have the
capacity to fulfill the ecological function, whereas in this case, the difference
between clean and polluted is that soil quality is such that 95% of the species in the
soil ecosystem are not exposed to concentration levels above their NOEC (with a
safety factor of 100 applied).
This second case has produced a scientific method and a new approach (risk
approach). Although the concentration levels distinguishing clean from polluted
have not changed (the target values are exactly the same as the reference values) the
definitions of these categories have changed, as they now refer to the protection of
fractions of species. What complicates the understanding of the resulting classifica-
tion is that in case the calculated target values are below the background levels as
calculated in the previous episode, these latter values are used as target values. Upon
doing so, the problematic aspects of the reference values; the fact that the substance
specific formulas developed to calculate the reference values included only two soil
bw.souren 18-09-2006 15:47 Pagina 156
characteristics (lutum and organic matter) and could not be used to differentiate
between natural occurrence of substances and anthropogenic enrichment,
remained.
156
Target and intervention values
Figure 6.5 Based on the concentration of substances, soil is classified either as clean or polluted. Target values distinguish
clean from polluted. Polluted soil is further classified into: severely and not severely polluted soil. Intervention values
distinguish severely from not severely polluted soil.
6.6 Conclusions
In Chapter 3, research questions 2 and 3 were formulated for the case studies.
2. What knowledge is labelled as usable knowledge?
3. What are the arguments applied in labelling and how do they relate to the
dimensions of the institutional context?
In this section the research questions are answered for the second case study. The
(disciplinary) background of knowledge that is labelled as usable is described. Also
the relation between the arguments applied in labelling and the institutional con-
text is given.
Related to this second case study, research question 2 (What knowledge is
labelled as usable knowledge?) could be answered as follows. The scientific knowl-
edge that is labelled as usable in this case study is experimental ecotoxicological
knowledge, mainly conducted on soil fauna. Besides the single species dose-
response experiments, the development of extrapolation methods has been boosted
bw.souren 18-09-2006 15:47 Pagina 157
through the labelling process. Compared to the previous case, the importance of
ecological research relative to soil science has increased enormously. The disciplinary
origin of the knowledge labelled as usable is clearly different from the first case.
There is a second important conclusion to draw with respect to the type of knowl-
edge: the discussions about the risk apporaoch and the species sensitivity distribu-
tions revealed a demarcation between regulatory science and research science. 157
Regulatory science has been labelled as usable.
chapter 6
Related to this second case study, research question 3 (What are the arguments
applied in labelling and how do they relate to the dimensions of the institutional
context?) could be answered as follows. As stated in the report by the Health
Council, the arguments in the labelling process concerned scientific aspects of the
compared methods. The Health Council tried to differentiate between the two
methods and phrased its argumentation in scientific terms (choice of parameters,
species selection, scientific methods), as pointed out in Section 6.3. In the alterna-
tive procedure proposed by the Health Council, the two methods were combined.
In practice the Van Straalen method was applied (after some modifications) by the
RIVM to calculate the concentration levels and to derive target and intervention
values. The arguments in the labelling process concerned the operationalisation of
the risk approach, and these arguments were related to the cognitive dimension of
the institutional context. As pointed out in the first section of this chapter and in
Chapter 4, the cognitive dimension in this episode was characterised by the intro-
duction and development of the risk approach. In part, the arguments for labelling
were related to the normative dimension. During the second episode the interaction
between science and policy intensified. The increasing number of involved actors,
the harmonisation of environmental quality standards and criticism on the princi-
ple of multifunctionality was reflected in the closer relation between science and
policy. It could be argued that the motivation of the authors of the Van Straalen
method to contribute to, and further the development of policy played a role in the
labelling of usable knowledge in the Health Council report. It could be claimed that
regulatory science was valued over research science in the development of soil qual-
ity standards in this second case study. Compared to the previous case study in
which the reference values were developed, the argumentation here did not refer to
the regulative framework. The integration of the Interim Soil Pollution Act did not
explicitly provide arguments in the labelling process. The normative dimension,
mainly characterised by the increasing number of involved actors, did not play a
decisive role in the labelling process in this case either. As we will see, this dimen-
sion became much more important in the third case study, when the soil remedia-
tion objectives were developed.
bw.souren 18-09-2006 15:47 Pagina 158
bw.souren 18-09-2006 15:47 Pagina 159
chapter 7
soil pollution originating from before 1987. Until the function-based approach was
officially adopted in June 1997, standards for soil quality were contingent on
human health and ecosystem health and applied to soil irrespective of the actual or
future land use. This was changed by the formulation of the soil remediation objec-
tives within the framework of BEVER. Soil quality now became contingent on land
160 use. Provinces and municipalities now were more explicitly involved in the devel-
opment of these new standards. This change was brought about by the criticism on
Soil remediation objectives
soil policy and soil quality standards that had arisen in the years before (see Chapter
4 for an explanation). The policy renewal included the development of new stan-
dards. In this case study the analysis is restricted to the labelling of usable knowl-
edge for the development of soil remediation objectives for immobile pollution.
‘land-use types’, ’user criteria’ and ‘minimal soil quality criteria’ in detail. The SROs
were published in 1999 and this publication demarcates the end of the case.
Where the previous case studies were concerned with further operationalisation
or modification, this third case study is about a drastic change of policy. In the
process of policy change and development of new instruments, several instances of
labelling usable knowledge could be observed. The analysis here is restricted to two 161
instances. First, the classification of land-use types is analysed. The reasons for
chapter 7
reducing the seven land-use types to four will be pointed out. Second, the labelling
of knowledge to developed SROs per land-use type is analysed in this chapter.
Two other issues that might have lent themselves for an analysis of labelling
processes concern the decision about the thickness of the topsoil layer to which
these SROs applied. A second and related issue is the distinction between mobile an
immobile pollution. The distinction between mobile and immobile became impor-
tant; mobile pollution can diffuse from one land-use type (with its specific quality
criteria) to the other land-use type where different quality criteria applied. When
the analysis described in this chapter was conducted both issues had not yet been
resolved. In sum, the labelling of usable knowledge for the classification of land-use
types and the corresponding SROs are analysed in this case study. The other two
issues are explained briefly in the second half of Section 7.2
In 1995, the renewal of soil policy started. This policy renewal was the long-await-
ed response to several critical reports from the past years on the actual course of soil
policy. The criticism was explicitly reported for the first time in 1993, by the
Werkgroep Bodemsanering (Werkgroep Bodemsanering 1993), In this report, the
principle of multifunctionality as an underlying concept for policy and standards
was criticised, but supported as well. A few years later, in 1996, an interdepart-
mental policy analysis concluded that the pace of the treatment was too low
(Min.VROM 1997) and caused stagnation in land use dynamics. According to this
analysis, the stagnation was caused by the high costs of treatment (related to the
high standards) and the long and complex administrative processes preceding actu-
al treatment. A second, related, criticism focused on the process of deriving stan-
dards and the representation of stakeholders (BEVER werkgroep 1997). The policy
renewal was organised as an open policy process named: BEVER, a Dutch acronym
referring to the beaver. The metaphor was used to point out that BEVER had to re-
establish connections and to build dams between the several policy fields and
involved stakeholders. BEVER provided the context for the development of new
standards. The policy renewal was framed by six aspects published in the Target
Perspective (Alons & Partners 1996):
bw.souren 18-09-2006 15:47 Pagina 162
Central to the renewal was to bring about a shift from ‘multifunctionality, unless…’
into a function-based perspective on soil quality. In June 1997, the Cabinet’s posi-
tion laid down the new course for soil policy and announced new standards. The
development of these standards, the SROs, was organised as an appraisal process.
Chapter 4 discussed this episode in detail and concluded with a summary along
three dimensions that is repeated here.
Table 7.1 The three dimensions of the institutional context in the third episode as described in Chapter 4.
Critical events, achievements and developments are given for each dimension.
In the Cabinet’s position in June 1997 the change from ‘fit for multifunctionality,
unless…’ into an assessment of ‘function-based quality’ was announced. One of the
issues that had to be addressed in operationalising the new soil policy was the devel-
opment of function-based soil quality standards. In the course of the project these
standards would also have to serve as objectives for the remediation of polluted sites.
The development of an appraisal process to establish remediation objectives became
the subject of Track A, coordinated by Core team A. This Core team, that consist-
ed of representatives from the Ministry of Public Housing, Spatial Planning and the
Environment, the Association of the Provinces of the Netherlands (IPO), the
Association of Netherlands Municipalities (VNG), Small and Medium Enterprises
(MKB) and the Confederation of Netherlands Industry and Employers (VNO-
NCW), had five tasks to accomplish with regard to the policy renewal:
bw.souren 18-09-2006 15:47 Pagina 163
chapter 7
the first two are discussed briefly in this section. The third issue (establishing land-
use types) is analysed in depth in this chapter. The fourth and fifth issue fall beyond
the scope of this thesis and are therefore not further addressed.
Once the function-oriented approach was adopted, the first issue to be resolved
was the distinction between mobile and immobile pollution. This was a difficult but
crucial issue, as it determined the options for treatment of substances and soils. It is
important to differentiate between mobile and immobile pollution in a function-
oriented approach since mobile pollution can diffuse between areas with different
land uses where different functions of soil are to be protected. Differentiation is also
important because of threats to the quality of the groundwater. Hence, a clear def-
inition of what is meant by mobile and immobile pollution was required. As the sci-
entific grounds for a distinction were too complex, the National Institute for Public
Health and the Environment (the RIVM) proposed a pragmatic approach and dis-
tinguished between ‘evidently mobile’ and ‘evidently immobile’ and a third group
consisting of situations that are neither. After measurements of concentrations in
the groundwater and assessments of actual diffusion the pollution is classified as
mobile or immobile. The deciding factor is the measured concentration in the
groundwater exceeding a specific standard (the RIVM proposed to use the inter-
vention values for this purpose) (Lijzen et al. 1999a). This approach was adopted by
Core team A. It was criticised by TCSP as it would introduce implementation prob-
lems. These problems would occur because of the relation between soil pollution
and earth streams23 policy (TCB 1998; Van de Haar 1999). Therefore, TCSP sug-
gested applying a case-wise approach and refraining from a generic approach. In its
advice TCSP argued not to develop a generic approach based on scientific knowl-
edge until the implementation practice asked for such generic approach to distin-
guish between mobile and immobile pollution. The criteria to distinguish between
mobile an immobile were not yet ready by the time the analysis of the empirical
material for this case study was finished. In Core team A’s final publication in 1999,
the distinction between mobile and immobile and the remediation objectives for
mobile pollution were addressed as important issues to be resolved.
1 Grondstromenbeleid.
bw.souren 18-09-2006 15:47 Pagina 164
thereby occur mainly in the groundwater. This is connected with, amongst other things, the
degree of acidity and absorbing capacity of the soil.
Definition
If we speak about an immobile contamination or a mobile contamination, we always allude
to a specific substance in a specific soil. It is therefore always a matter of specific situations.
Immobile contamination
A situation in which substances do not dissolve or dissolve poorly in water and do not evap-
orate. These substances cannot spread or at least not readily and thereby often occur in the
topsoil. Direct contact can lead to exposure
Mobile contamination
A situation in which substances dissolve well in water. The substance penetrates the soil with
rainwater and can spread with the groundwater. These substances therefore usually occur in
the subsoil.
Volatile contamination
A situation in which substances dissolve well in water and evaporate easily. The substances
can then spread via the groundwater into the topsoil again.
The second issue to be resolved was the distinction between subsoil and topsoil. The
topsoil is the upper soil layer within which plants root and most soil fauna lives. In
soil policy the distinction between subsoil and topsoil was never made before; soil
policy applied to topsoil. In the third episode the distinction became relevant to
make because the connotation of soil began to change from an environmental
resource to an economic resource. Building and construction as economic activities
are not limited to topsoil, but increasingly take place in subsoil. As a consequence
the distinction between topsoil and subsoil became relevant. The subsoil refers to
deeper soil, where digging and construction works take place. The standard
approach to be followed for the treatment of an immobile pollution was to create a
bw.souren 18-09-2006 15:47 Pagina 165
surface layer (with SRO as soil quality standard). The thickness of the surface layer
depended on the soil-use type, as can be seen in Table 7.2. In its advice, TCSP crit-
icised this proposal for the relative thin surface layer. TCSP argued that activities
like building and tree growth were insufficiently taken into consideration and
advised to increase the thickness of the surface layer. TCSP advised a standard thick-
ness of 1.5 meter to which the Soil Remediation Objective would apply. Core team 165
A did not adopt that suggestion. In addition, TCSP considered a surface layer
chapter 7
approach inadequate for agriculture and nature. Apparently, the Core team did not
adopt that suggestion either and maintained its proposal for the thickness of the
surface layer in its final report.
Table 7.2 Soil use types and target values for the thickness of a surface layer (BEVER regiegroep 1999). The
four land-use types are explained in Section 7.3.
The third issue that had to be resolved was the establishment of land-use types and
the remediation objectives. The development of these remediation objectives and
the land-use types is analysed in depth in the following sections.
The labelling of usable knowledge developed for these remediation objectives for
immobile pollution consisted of two steps. In the first step, the soil-use types were
identified. The RIVM proposed to distinguish seven soil-use types and developed
user criteria and minimum soil quality criteria. In soil policy a distinction in soil
functions had been made in the first episode (see Chapter 4, episode 1): a carrier
function, water supply, production (agriculture and mining) and an ecological func-
tion had been distinguished, but these were never translated to land use and specif-
ic soil use. In the first episode, under the guiding principle of multifunctional soil
quality, the ecological function was identified as the most vulnerable. This most vul-
nerable function was used to derive standards for soil quality. The identification of
the other functions became irrelevant. In soil policy the carrier function, water sup-
ply function, production function (agriculture) and the ecological function had
been distinguished, but these were never translated to land use or to specific soil use.
bw.souren 18-09-2006 15:47 Pagina 166
In the third step, the RIVM derived minimum soil-use requirements for each soil-
use class (step 3) and an operationalisation for the soil quality criteria (step 4). For
example, for the first class of soil use (housing with vegetable garden) the RIVM
posed as a soil-use requirement that the consumption of home-grown crop would
amount to 10-50% of total crop consumption. As a contrast in the second soil-use
class, a maximum of 10% of total crop consumption consists of home-grown crops.
Such criteria were developed for all seven classes. In the fourth step (Identification
of soil quality criteria) four different soil-use criteria were derived.
In other words, soil quality for each land use class, would have to be evaluated for
these four criteria. This distinction into four quality criteria differs from the distinc-
bw.souren 18-09-2006 15:47 Pagina 167
tion into two quality criteria used in the previous case study, where a differentiation
was made between the criteria: risk to human health, risk to ecosystem health (main-
ly operationalised as risks for soil fauna) and risk of diffusion of pollution (Chapter 6,
Section 6.4). The first criterion (Human health soil quality) concerns human health.
Further explanation of this criterion is beyond the scope of the thesis.
The second criterion (Soil quality criterion for plants) is remarkable. In this case 167
study a separate criterion was included for plant growth. This is illustrative of the
chapter 7
difference between the second and third episode. In the second (and first) episode,
plant growth and soil quality was studied in relation to agronomic issues and agri-
cultural use of soil. This relation was not studied in the context of the protection of
nature and environment. The body of knowledge on plant growth and soil quality
as developed at Wageningen University was largely out of sight once the ecological
function was selected to be the most vulnerable. In addition, as described in the sec-
ond case study, scientists refrained from including plant scientists in the previous
episodes as this would complicate and fragment the available resources for scientif-
ic research. For these reasons, plant growth and phytotoxicity (toxicity for plants)
was not explicitly included in the previous cases. It is therefore remarkable that it
appeared as a separate criterion here. In the new approach, plant growth, either for
recreational, nature or consumption purposes became a distinctive characteristic of
soil use. However, as we will see, this was a short-lived phenomenon only.
The third soil quality criterion (ecological soil quality) concerns ecotoxicologi-
cal risk assessment as developed in the previous episode. The RIVM proposed three
different and alternative methods to assess ecological soil quality. The first was to
apply the approach used to calculate the target and intervention values. The target
values are set at 1% of the HC5 (the concentration above which 5% of the species
in the system is exposed to concentrations above their No-Observed-Effect-
Concentration (NOEC)). For the least vulnerable soil use, other HC values could
be used (HC10, 20 or 50). The second alternative proposed in the RIVM study was
to identify key species and key processes per soil use and to establish the concen-
tration levels at which a certain percentage of the species is affected. This approach
was developed in a study commissioned by TCSP (Van Hesteren et al. 1998). The
third alternative took a different approach and focused on actual site-specific risks
instead of the potential risks calculated with the first two alternatives. This method
was developed by researchers from the RIVM, RIZA and IBN. The core of the
method was an integrated assessment of actual risks based on on-site chemical, eco-
logical and ecotoxicological measurements on the spot (Rutgers et al. 1998). The
first alternative was already available and did not require further research. The sec-
ond alternative required some additional research, but most of the data were already
available and similar to the data required for the first alternative. The third alterna-
tive concerned conceptual and ambitious work in progress. Application of this third
alternative would require additional time and resources to further develop the
bw.souren 18-09-2006 15:47 Pagina 168
Table 7.3 Approaches to calculate the remediation objectives for the seven soil-use types developed by the RIVM. MTReco,
phytotoxicity, HC50, Other LAC, Ecoprocess, refer to ecotoxicological criteria. BOOM refers to: requirements in relation to
recycling organic waste. BAGA refers to: Decree on dangerous waste. Both BOOM and BAGA are grouped as ‘additional
criteria’. Human refers to human health quality criterion.
1 2 3 4 5 6 7
Housing with Housing with Housing Industrial Public green Agriculture Nature
vegetable garden areas space
garden
Cr MTR eco MTR eco HC50, HC50, Ecoprocess MTR eco Ecoprocess
Ecoprocess Ecoprocess
Ni MTR eco MTR eco HC50 HC50 BOOM MTR eco phytotoxicity
Cu MTR eco MTR eco HC50 HC50 phytotoxicity MTR eco other LAC
Hg MTR eco MTR eco HC50 BAGA BOOM MTR eco other LAC
Pb human MTR eco HC50 HC50 human MTR eco other LAC
chapter 7
garden and housing with garden was difficult to establish and difficult to control.
TCSP advised to differentiate between intensively used and extensively used land
use. In June 1999, Core team A asked the RIVM to develop a new classification and
posed that the number of soil-use types had to be reduced. After this intervention
by the Core team, the RIVM clustered the soil-use types and produced the so-called
Core team variant 2:
In response to this outcome, the Core team stated that exposure in Cluster IV was
negligible and that, consequently, no standards had to be derived.
Table 7.4 Two approaches to calculate the remediation objectives for the three soil-use clusters developed by
the RIVM in response to Core Team variant 2. HC 50, and LAC refer to Ecotoxicological criteria. Human refers
to Human health quality criteria. The three soil-use clusters grouped the previous soil-use types as follows:
Cluster I: housing with vegetable garden, housing with garden, agricultural areas, nature areas. Cluster II:
housing without garden, industrial areas/infrastructure with open surface. Cluster III: public green space and
recreation.
During the project Core team A asked the RIVM to make visible how changes in
the soil-use requirements affected the height of the soil remediation objectives. The
RIVM calculated a number of variants making clear that considerable differences in
the height of the standards could be produced by changing the soil-use require-
ments. One of these variants was based on a proposal by Core team A (Core team
170 variant 1) about what soil uses to include and which ones to exclude. These inter-
ventions by the Core team are clear examples of boundary work between science
Soil remediation objectives
and policy in the development of these standards: Who had the authority to iden-
tify the number of classes in the soil-use typology? If the RIVM was given the task
to produce a classification, why did the Core team intervene with a directive about
the number of classes? This issue is discussed in Section 7.5. In addition, the Core
team stated that the ‘additional soil-use criteria’ were irrelevant. The RIVM went
through the whole procedure again and proposed a new classification, given in
Table 7.4.
In commenting on this proposal, the Core team now voiced its wish to make a
separate class for agriculture and nature. This was another intervention by the Core
team that was not welcomed by the RIVM. The resulting classification (Core team
variant 3) was used to proceed with the development of soil remediation objectives.
Core team A now used the following four categories of land use:
1 Housing and intensively used (public) green space (subset of the above Clusters
I and III)
2 Extensively used (public) green space (subset of the above Cluster III)
3 Construction and pavement (subset of the above Cluster II)
4 Agriculture and nature (subset of the above Cluster I)
types where both human and ecosystem exposure is limited. These four categories
of land use have been used for the development of soil remediation objectives. In
Section 7.4 the final proposal for the soil remediation objectives is given.
Besides the establishment of the remediation objectives, mobile and immobile
pollution, and the thickness of the surface layer, two more issues had to be resolved
as mentioned at the beginning of Section 7.2. The fourth issue was the distinction 171
between a standard treatment and a customised approach. The fifth issue was the
chapter 7
distinction between a customised approach per case, and a customised approach per
area. The standard approach consisted of the application of a surface layer on top of
the polluted soil. The differentiation between a tailor-made approach per case and
per area entailed the risk of inequality of soil quality. Location-specific approaches
could result in a different soil quality that differs per individual site. The legal
responsibility of national government (in this case, the Ministry of Public Housing,
Spatial Planning and the Environment) to safeguard the generic soil quality urged
the ministry to set the degrees of freedom in location-specific treatments.
The results of the work by Core team A were published in 1999: From Funnel
to Sieve (BEVER regiegroep 1999). The title of the document refers to the differ-
ence between a funnel and a sieve: The flow of treatment projects can get blocked
if a large project blocks the funnel. Once a large project blocks the funnel, not even
small and simple projects can pass through. Through a sieve, the relative simple and
small treatment projects can pass, leaving the large and complex projects behind for
a customised approach. The metaphor of funnel and sieve is used to illustrate the
attempt to reduce the stagnation that can result from blocking the funnel by replac-
ing it by a sieve.
The report ‘From Funnel to Sieve’ meant to set the boundaries of the breathing
space for the formulation of location-specific treatment. The report did not treat all
aspects of the work of Core team A as some issues were not yet resolved. For
instance, the customised approaches, per case and per area were developed later as
they turned out to be thorny issues. In the report, not more than a start was made
with the appraisal process for subsoil, i.e., mobile pollution. The concept of ‘stable
end situation’ was introduced, to denote that treatment would have to be geared
towards stabilisation of the plume of mobile pollution, spreading from the source.
The policy regarding mobile pollution was not fully fleshed out.
At this stage, the TCSP commented on the report by the Core team. The com-
mittee stressed to develop a policy for the monitoring and ‘Aftercare of mobile pol-
lution’ (TCB 1998). In addition, the committee anticipated a ‘new’ attitude to soil
quality, in which environmental quality became subordinate to economic value.
The connotation of soil began to include soil as a resource for social and economic
development. The committee finally urged to reflect on this while further develop-
ing the practice of active soil management.
bw.souren 18-09-2006 15:47 Pagina 172
In the report by Core team A, the following land-use types had been distinguished.
The soil remediation objectives for the first two land-use types were published in
their report. For the third function no standards were derived. The motivation was
that there was no exposure, as it concerned paved surfaces. For the fourth function
it was initially decided to apply the LAC-signal values for the agricultural activities.
However, these values were being evaluated at that moment, and the final decision
about the soil remediation objectives were postponed until the reviewed LAC sig-
nal values were established.
Table 7.5 Approaches applied to derive soil remediation objectives for the four land-use types finally proposed
by the RIVM 1 (Lijzen et al. 1999b).
1 2 3 4
Housing and intensively Extensively used Construction and Agriculture
used (public) green space (public) green space pavement and nature
Table 7.5 shows the variety of approaches to calculate standards for soil quality. The
LAC values are standards developed and applied in agricultural policy. In this policy
field, standards for soil quality are calculated based on standards for substances in food
products. A differentiation is made between different agricultural products; those for
human use (LAC-food), animal consumption (LAC-fodder), and phytotoxicity (LAC-
phytotoxicity). The HC50 values have been used to derive the intervention values (see
Chapter 7). The MTL-human (used to calculate the SRO for lead (Pb) in land-use type
bw.souren 18-09-2006 15:47 Pagina 173
1 refers to the Maximum Tolerable Level for human (children’s) health. Table 7.6 gives
the concentration levels calculated with the above approaches. HC50 and MTL levels
are given for standard soil. The correction formulas for different soil types as developed
for the reference values and applied as correction factors for target- and intervention
values apply (see Chapter 5 for a detailed explanation of these soil type correction fac-
tors). LAC-values are given for clay as the best approximation of standard soil (10% 173
organic matter, 25% lutum content).
chapter 7
Table 7.6 Soil remediation objectives for the four land-use types compared to the target and intervention
values (Lijzen et al. 1999b). All concentrations are given in mg/kg dry soil.
1 2 3 4
Housing and Extensively Construction Agriculture Target Intervention
intensively used used (public) and pavement and nature values values
(public) green green space
space
Cd 1 12 - 0.5-10 0.8 12
Hg 2 10 - 2 0.3 10
As 40 40 - 30-50 29 55
What stands out in these tables is the variety of the scientific approaches used to cal-
culate the SROs reflecting the combination of models and approaches developed
before.
The soil remediation objectives were produced within the context of the BEVER
project. The standards were regarded as one of the outcomes of the soil policy
renewal and therefore had to fit, more than before, administrative processes.
bw.souren 18-09-2006 15:47 Pagina 174
The incentive to derive soil remediation objectives was the recognition that the avail-
ability of soil of a certain quality is crucial to processes other than from the environ-
mental policy subsystem alone. Housing, construction, agriculture; all depended on
174 soil quality. Stagnation of cleanup because of environmental considerations led to
stagnation in these policy subsystems and this was no longer acceptable. The conno-
Soil remediation objectives
One of the initiatives that led to the formulation of soil remediation objectives was
the critical comment on existent soil policy by the Association of Netherlands
Municipalities (VNG) made as early as 1992 and 1995. The VNG opposed the
then current soil policy as it frustrated building and construction activities. A clas-
sic example illustrating the implementation problem was that in order to obtain
permission to build a small extension to a house such as a veranda, the soil quality
had to be checked, and if any contaminant concentration exceeded the intervention
value, no permission could be given and further analysis was required to determine
the urgency of the treatment of the pollution. It was generally acknowledged that
the application of these standards in such situations was beyond their purpose. The
VNG used such dramatic examples to encourage the discussion about function-
based soil quality standards.
The Directorate General of the Environment within the Ministry of Public
Housing, Spatial Planning and the Environment took up the challenge, and, in dis-
cussion with the Directorate General of Housing within the same ministry respond-
ed to the VNG with the proposal to develop the soil remediation objectives. They
bw.souren 18-09-2006 15:47 Pagina 175
did not adopt the standards proposed by the VNG. This response created the
momentum needed by the VNG and the IPO to become more active and authori-
tative in policy formulation. From interviews during the research, it became clear
that the Ministry of Public Housing, Spatial Planning and the Environment strug-
gled with finding a new niche now that new actors had been invited at the standard-
setting table. In other words, one of the issues characteristic of this case study was 175
the clarification of the roles of the national government in relation to regional and
chapter 7
local authorities. On the face of it, part of the decision-making authority was trans-
ferred from national government to local and regional governments.
In the BEVER project, three meetings were scheduled with experts. Each meeting had
a specific subject. Here, the first meeting is relevant. In a group of 14 experts a dis-
cussion was organised on SROs and the surface layer. The expert group represented
the stakeholders; municipalities, provinces, the Ministry of Public Housing, Spatial
Planning and the Environment, Industry, Environmental NGOs, Core team A, and
the TCSP. Scientists employed at universities and experts on soil were not directly rep-
resented. The members of the expert meeting were experts with respect to the devel-
opment and implementation of soil policy, more than with respect to soil quality in a
scientific sense. The qualification of expert shifted from scientists, knowledgeable on
technical aspects of risk assessment, towards people who are knowledgeable on soil
policy and implementation. These two characteristics of the context are crucial to an
understanding of the labelling of usable knowledge in this third case. It is apparent
from the documents and interviews that there were difficulties in defining whose task
it was to define the land-use types, the user criteria and the quality criteria (see (Lijzen
et al. 1999a) and correspondence of the chairperson of Core team A with the project
manager at the RIVM (Roeters 1999; Swartjes 1999)). The interaction between the
RIVM and Core team A was troubled by communication problems that could be
traced back to uncertainties about the division of roles and responsibilities for aspects
of the development of the SROs. It was not only the limitation in time that altered
the co-production seen so clearly in the second case study on the development of tar-
get and intervention values. The envisaged policy change was not a cognitive change
as much as the previous two cases. The six aspects listed in the Target Perspective that
set the contours for the policy change were almost exclusively about process changes.
The normative dimension of the context dominated the policy renewal. In unfolding
the process of labelling usable knowledge it has become clear that the relation between
science and policy, notably the relation between the RIVM researchers and Core team
A was unclear. In one of the BEVER draft reports the following argumentation was
given for the labelling of usable knowledge:
bw.souren 18-09-2006 15:47 Pagina 176
The above choices enable an interpretation of the SROs resembling the intervention values as
much as possible. This prevents a complete new research programme having to be installed to
provide scientific underpinning for the SROs. The information for these parameters (HC50 ,
MTL, LAC) has already been discussed for other purposes (intervention values).
(BEVER regiegroep; From Funnel to Sieve, February 1999 p. 39)
176
Although the argumentation for labelling has not changed, in the final version of
Soil remediation objectives
From Funnel to sieve a different signal concerning the outlook for research activi-
ties was given to researchers.
The choices made above make an interpretation of the SROs possible which comes as close as
possible to existing soil quality criteria and methods. …For the sake of future improvements to
the SRO system, therefore, a research programme is being developed for which the Ministry of
Public Housing, Spatial Planning and the Environment will be responsible.
(BEVERregiegroep; From Funnel to Sieve, October 1999 p. 66)
The responsibility of Core team A was to decide about the land-use types, the user
criteria and the related minimum soil quality criteria. They did this in close contact
with the RIVM. After deliberations within Core team A and the BEVER control
and steering group, the Core team decided that the number of functions should be
reduced to four, that the Core team had to decide about the user criteria and that
the RIVM would then be invited to derive minimum soil quality criteria. Similar to
the previous two case studies, significant steps in the labelling of usable knowledge
were taken in an early stage. The formulation of policy goals or objectives implied
what was going to be usable knowledge. In this third case study, the degrees of free-
dom for scientists to produce new knowledge were reduced to a minimum, so to
speak. Core team A asked the RIVM to provide scientific underpinning for a func-
tion-based approach in less than a year. In this case study, boundary work took place
between regulatory science and policy. The distinction of the land-use types made
this boundary work visible. It was unclear at the start of track A how responsibili-
ties were demarcated resulting in an intense debate between the RIVM and Core
team A about these responsibilities.
In the Target Perspective laying the groundwork for the development of the SROs,
a more participatory appraisal process was advocated. Provincial and local authori-
ties claimed a position at the table. Other parties also became involved, such as the
representatives of Small and Medium Enterprises (SMEs) and the Confederation of
Netherlands Industry and Employers (VNO-NCW). All parties with stakes con-
bw.souren 18-09-2006 15:47 Pagina 177
cerning the quality of soil were invited to participate. Together with the broadening
of policy fields that use soil quality standards, this increased number and diversity
of participating actors was meant to increase the use and acceptance of soil quality
standards and reinforce these actors’ commitment and involvement. It has also
made the development of standards an even more complex and time-consuming
project. Such increase in the numbers and diversity of actors requires a careful def- 177
inition of the tasks, responsibilities and roles of all parties involved, as well as of
chapter 7
what is expected of them.
The meaning of soil quality standards changed in several ways. First and foremost
the generic reach of soil quality standards was traded in for a function-based
approach. Exceeding the standard in the previous case studies was an indication of
a potential risk. In the previous case studies, standards were developed to indicate
actual risk. Exceeding the intervention values indicated that over 50% of the species
was exposed to above their NOEC. This was interpreted as an indication of poten-
tial risk and provided grounds to schedule treatment. Actual and local risk assess-
ment was not determined. The grounds for treatment were based on standards that
were grounded in generic and potential risk indications. In the present case study,
the grounds for treatment shifted towards the establishment of actual and local
risks. This is a less precautionary approach. Soil pollution has shifted from an envi-
ronmental problem towards an economic and social problem; solving the environ-
mental problem has been traded for solving an economic and social problem, under
the flag and responsibility of environmental policy. This shift is materialised in the
development process of standards that I have unfolded in this case study. I uncov-
ered the argumentation for the calculation of the different standards for land-use
types in an attempt to clarify the meaning behind the figures of the standards.
Standards simplify and reduce complex decision-making to dichotomies. That is the
strength of standards. Once soil policy develops other instruments to support com-
plex decision-making, the strength of standards as policy instruments diminishes.
A second shift in the meaning of standards is that the soil remediation objectives
have made soil quality depend on land use; a spatial planning perspective has been
included in environmental policy-making. This will invoke new dynamics in soil
policy. On the one hand because SROs, like any quality standard, have a performa-
tive meaning and will change soil policy development and implementation. Figure
7.1 shows the proliferation of the classification of soil quality. The implementation
of SROs has increased the complexity of the framework for soil quality standards
and suggests that this will simplify the implementation of soil treatment.
bw.souren 18-09-2006 15:47 Pagina 178
Figure 7.1 Classification of soil quality after the introduction of SROs. First of all, the SROs classify soil into 4 land-use types.
For land-use type 1 (housing and intensively used public space) and 2 (extensively used public space) soil quality is classified
into soil that meets target values, soil that meets SROs, soil that is severely polluted (exceeding the intervention values) and
soil that is severely polluted and has to be treated urgently. For land-use type 3 (construction and pavement) no SROs are
derived. Even if soil is severely polluted and qualifies for urgent treatment, no target for treatment is given. For land-use
type 4 (agriculture and nature), soil quality is classified into: soil that meets the target values; soil that exceeds the
intervention values; and soil that is severely polluted and has to betreated urgently. The question mark of the fourth class
refers to the fact that for land-use type 4, the soil remediation objectives are determined per case.
7.6 Conclusions
In Chapter 3, research questions 2 and 3 were formulated for the case studies.
This section answers the research questions for the third case study. The (discipli-
nary) background) of knowledge that is labelled as usable is described. Also, the
relation between the arguments applied in labelling and the institutional context is
given.
Related to the second case study, research question 2 (What knowledge is
labelled as usable knowledge?) can be answered as follows. For the distinction of
land-use types, approaches from spatial planning were labelled as usable for the clas-
sification. In the light of policy development in the third episode this is not sur-
bw.souren 18-09-2006 15:47 Pagina 179
prising; perspectives from spatial planning policy were introduced in soil policy,
moreover, in one of the BEVER projects approaches in spatial planning policy were
valued over environmental policy (see Chapter 4, Section 4.3.2). From a soil policy
perspective it is interesting to compare the development of this typology with the
soil function typology developed in the first episode (see Chapter 4, episode 1 and
Chapter 5). Several typologies were developed at that time and co-existed. The need 179
to further elaborate on that classification at the time was absent; once the ecologi-
chapter 7
cal function had been qualified as the most restrictive and therefore the function for
which a protective soil policy would have to be put in place, it was virtually irrele-
vant to develop the typology further. To my knowledge, a revision or reconsidera-
tion of the soil function typology developed in the first episode was not part of the
development of the function-based typology in this case study. The observation that
the typology developed in episode 1 was not used in this third episode further sup-
ports my conclusions that the principle of multifunctionality was useful and even
crucial in the first episode to establish a position for soil policy (within the Ministry
of Public Health and the Environment in the 1980s and also in relation to the
Ministry of Agriculture, Nature, and Fisheries). For the development of the SROs
scientific knowledge related to flanking policy fields was labelled as usable; LAC
standards were labelled as usable, together with the scientific knowledge that had
been labelled usable in the previous case study: ecotoxicological knowledge.
Research question 3 (What are the arguments applied in labelling and how do
they relate to the dimensions of the institutional context?) can be answered as fol-
lows. The regulative dimension plays a role, insofar as the revision of the Building
Materials Decree made it clear that standards for soil quality applied to that legal
framework as well. This provided an argument to develop standards that took the
interests from that sector into consideration. The arguments for labelling manly
concerned the normative dimension. The increasing number and diversity of actors
and policy fields related to soil quality standards (notably the Building Materials
Decree) made it clear that standards had to facilitate the cooperation of these actors,
which urged for the approval of involved parties in the development of these stan-
dards. This became a point of departure through the Target Perspective. It was the
difficult task for Core team A to develop these standards in a fast changing envi-
ronment taking these different perspectives and interests into consideration.
Arguments related to the cognitive dimension were apparent; soil was reframed
from an ecological, environmental compartment, worthwhile to be protected as a
resource for economic activities and development. This was reflected in the devel-
opment of a land use typology that reflected not only soil as an environmental com-
partment but also as an economic resource.
bw.souren 18-09-2006 15:47 Pagina 180
bw.souren 18-09-2006 15:47 Pagina 181
chapter 8
This chapter discusses the main conclusions of the research. The chapter consists of
three sections. Section 8.1 answers the research questions. Section 8.2 discusses
these answers in terms of the perspective and guiding question from Chapter 1. The
third and final section of this chapter provides a reflection on the methodological
and theoretical approach.
How can we understand the labelling of usable knowledge for the development of
soil quality standards in terms of boundary work between science and policy and in
terms of the relation between regulatory practice and its institutional context?
In Chapter 3 a literature review was included as well. The conclusion of that review
was that the concept of boundary work was insufficiently fleshed out as an analyti-
bw.souren 18-09-2006 15:47 Pagina 182
cal perspective. As a way forward it was proposed to complement it with the concept
of institutional context. From that latter perspective the labelling of usable knowl-
edge could be interpreted as a process within regulatory practice that in turn was
embedded in an institutional context. In doing so, it became more than just inter-
esting to understand the arguments applied in labelling as boundary work between
182 science and policy. The arguments applied in labelling now also anchored regulato-
ry practice to its institutional context, in which a variety of actors, interests and issues
Conclusions and discussion
Throughout the research focus has been on the application of the institutional con-
text as a concept to further our understanding of the interaction between science
and policy in labelling usable knowledge.
In Chapter 4 the recent history of setting standards for soil quality was described,
which is organised in three episodes. Each of these episodes was characterised in terms
of the three dimensions. A short and simple answer to the first research question is not
possible. Table 8.1 gives an overview of the critical events, achievements and develop-
ments on the regulative (first row), cognitive (second row) and normative dimension
(third row). The table is explained more extensively in the text below.
The first row concerns the regulative dimension, and reveals a developing policy
field; in the first episode the legal framework (Soil Protection Act and Interim Soil
Pollution Act) was constructed. As explained in Chapter 4, Section 4.1.1, the devel-
opment of a legal framework for soil policy was delayed. First, soil was initially per-
ceived as a resource available for infrastructural works, for agriculture and mining.
bw.souren 18-09-2006 15:47 Pagina 183
Table 8.1 Assembled from the tables in the concluding sections of each episode in Chapter 4. For each episode and
dimension critical events, achievements and developments are listed.
Regulative • Interim Soil Pollution Act • Integration of Interim Soil • Revision Soil Protection
(1983) Pollution Act and Soil Act (1994) 183
• Soil Protection Act (1987) Protection Act (1994) • Cabinet’s position (1997)
chapter 8
• Building Materials Decree
(1999)
Cognitive • Multifunctionality • Risk approach • Function-based quality
• Multifunctionality • Risk approach
• Multifunctionality
Normative • Carving out a department • Active soil management • Active soil management
(sector) for soil quality at the • Increase in number of actors • Soil policy renewal:
Ministry of Public Health involved in policy development BEVER, six aspects from
and the Environment (notably the VNG, the IPO) Target Perspective
• Disputes between ministries • Integration of environmental • Soil research programmes
over authority to regulate policy fields (PGBO, NOBIS, SKB)
soil quality • Criticism with regard to
• Establishing the Technical abstract and insufficiently
Committee on Soil operational principles guiding
Protection soil policy
• Soil research programmes • Soil research programme
(Soil Protection, Soil (Netherlands Integrated Soil
Ecology, Netherlands Research Programme SPBO)
Integrated Soil Research
Programme SPBO)
A closer look at the second row (cognitive dimension), reveals the increasing num-
ber of concepts (principles). In the first episode, the principle of multifunctionality
was introduced as the guiding principle in soil policy. In the second episode, the risk
approach was introduced in environmental policy and applied to soil policy as well. It
was introduced to set priorities in environmental policy by ‘defining’ different risk lev-
184 els (the negligible level (NL) and the maximum tolerable level (MTL)). In addition,
the risk approach was introduced to harmonise the development of standards for the
Conclusions and discussion
three environmental compartments (soil, air and water). The risk approach did not
replace the guiding principle of multifunctionality, as it had a wider reach and applied
to environmental policy in general. In the third episode, the concept of function-
based quality was introduced as part of a renewal of soil policy. Like the risk approach,
this concept also did not replace the earlier concepts, but complemented these.
Function-based quality introduced a differentiation between the functions of soil.
Whereas previous concepts stressed the sameness of soil quality irrespective of land
use, the concept introduced in the third episode did just that. It led to a differentia-
tion of soil quality standards for different land-use types.
It could be argued that the concept of multifunctionality was the point of depar-
ture, not only for policy development, but also for the formulation of the research
agenda of the largest soil research programme, the Netherlands Integrated Soil
Research Programme; SPBO. This statement must be qualified immediately, as it
should be noted that it was not so much the principle of multifunctionality that was
used as a point of departure, but rather the identification of the ecological function
as the most vulnerable one. This has directed the development of soil research that
began to focus on the ecotoxicological effects of potentially toxic substances. As was
shown in Chapter 7, the concept of function-based quality as such referred not so
much to a development of new scientific knowledge, but mostly to the practice of
implementing standards. Compared to the previous two concepts, this concept was
introduced to facilitate the progress of soil policy and treatment and available sci-
entific knowledge was used to underpin this concept by developing an operational-
isation consisting of a land use typology and related soil quality standards. It must
be noted here, that the development of alternative methods to assess site-specific
and actual risks was stimulated meanwhile.
Standards for soil policy are treated in this thesis as instruments in soil policy,
which in turn is embedded in environmental policy. In this ‘hierarchy’ (see Figure
8.1) the different cognitive concepts discussed in this thesis (multifunctionality, risk
approach, function-based quality) are located in different positions. In Figure 8.1
the cognitive concepts are positioned in this hierarchy with environmental policy
principles at the bottom and soil quality standards at the top. The concepts at the
bottom are generic principles in environmental policy (‘limits to growth’ and ‘sus-
tainability’). Towards the top of the triangle the concepts are more specific in soil
policy and soil quality standards. For instance, in the second episode the risk
bw.souren 18-09-2006 15:47 Pagina 185
approach was introduced. This concept pertains to environmental policy. The risk
approach is therefore more generic than the principle of multifunctionality which
pertains to soil policy only, and is therefore positioned between ‘multifunctionality’
and ‘limits to growth’. In the third episode, the principle of multifunctionality was
complemented by the concept of function-based quality insofar as the latter applies
to immobile pollution originating from before 1987 (the year the Soil Protection 185
Act was implemented).
chapter 8
Soil quality Reference values
standards as policy
instruments
Soil policy
principles Multifunctionality
Environmental
policy principles Limits to growth
Multifunctionality
Risk approach
Limits to growth
Soil remediation objectives
Function-based/
(multifunctionality)
Risk approach
Sustainability
Figure 8.1 Representation of the cognitive dimension for the three successive episodes. Each ‘triangle’ must
be looked at as a representation of an episode. The upper left triangle represents the first episode. In the
middle is the second episode and the third episode is on the bottom right. At the bottom of each ‘triangle’ are
environmental policy principles. Towards the top of the triangle, the concepts get more specific for soil policy,
and finally for soil quality standards. In the first episode the reference values are developed as standards for soil
quality and the principle of multifunctionality is developed. It is specific for soil policy, and used directly as a
principle for the development of the reference values. In the second episode, target and intervention values are
developed and the risk approach is introduced. This concept has a wider reach compared to multifunctionality,
as it pertains to the environmental policy field in general. At the same time it has directed the development of
target and intervention values. In the third episode soil remediation objectives have been developed and the
function-based approach has been introduced as complementary to multifunctionality. Again, this concept was
very specific for soil policy and has directly influenced the development of the soil remediation objectives.
bw.souren 18-09-2006 15:47 Pagina 186
Now that the second row of Table 8.1 (cognitive dimension) is explained in more
detail, finally, the normative dimension (the third row from Table 8.1) is explained.
This lower row of the table summarises the critical events, achievements and devel-
opments in the normative dimension. The three decades could be characterised by
three developments.
186
1 The development from a sectoral to an integral policy field.
Conclusions and discussion
Each of these will be elaborated on. The first is the development from a sectoral to
an integral policy field. In the first episode, the development of soil policy was sec-
toral. Soil, water and air (protection) policies were not integrated and fell under dif-
ferent ministries. Soil protection trailed behind air quality and water quality policy,
and had to acquire a position in environmental policy. Typical were the disputes
between the Ministry of Public Health and the Environment, and the Ministry of
Agriculture and Fisheries about the development of an overarching Soil Protection
Act (see Chapter 4, episode 1). In this first episode, this carving out of a (cen-
tralised) soil policy was characteristic. In due course, the relations with other envi-
ronmental policy fields strengthened, illustrated by the joint publication of soil
quality standards and water quality standards in 1991 (Min.VROM 1991).
Following this, soil was increasingly framed as an economic resource, rather than as
an exclusive environmental resource in the third episode. In the description of the
second and third episode in Chapter 4, a number of reports and developments were
discussed to illustrate this. Actors from the policy fields of physical planning and
housing became increasingly involved in soil policy and vice versa.
The second development is the decentralisation of soil policy development. In
the first episode, the ministry was the central actor. In the second and third episode
the role of the Association of the Provinces of the Netherlands (IPO) and the
Association of Netherlands Municipalities (VNG) increased. These government lev-
els were involved in implementation, but now claimed a position in policy devel-
opment. Their involvement in policy development culminated in the development
of ‘active soil management’; an approach in which the management of soil as a social
and economic resource is professionalised and attuned to the practices in regional
and local treatment of soil pollution. In the development of the SROs, both
Associations played an important role.
The third development is the increased interaction between soil research and
policy. In the first episode, the establishment of the TCSP in the Soil Protection Act
was illustrative for the development of scientific knowledge and for the develop-
ment of the relation between science and policy. The establishment of this com-
mittee in the Soil Protection Act caused a reorientation of scientific knowledge for
bw.souren 18-09-2006 15:47 Pagina 187
policy about soil quality from a primarily agricultural orientation towards an envi-
ronmental orientation. This was also reflected in the development of government
funded research programmes that could be interpreted as attempts to ‘create a coali-
tion of engaged scientists’ (see quote in Chapter 4). Secondly, the establishment of
this advisory committee embedded the policy field in science. Thereby soil policy
came to resemble the policy fields of air and water quality, where scientific adviso- 187
ry bodies had already been established.
chapter 8
This section answered the first research question about the characterisation of
the institutional context. Now that the development of the institutional context is
characterised, we can get back to the labelling process taking place in regulatory
practice. The disciplinary background of the knowledge labelled as usable in the
development of the respective soil quality standards is given in Section 8.1.2 in
answer to research question 2.
project measuring concentration levels of heavy metals carried out at the National
Institute for Nature Management (RIN) was presented in the interviews as excep-
tional and visionary. Such projects were slightly beyond the scope of the institutes
conducting such inventories, mainly because they were made in ‘relatively undis-
turbed areas’, such as nature reserves. As soil research was oriented towards agricultural
188 practice, inventories in nature areas did not abound, so to speak.
Things changed rapidly after the uncovering of the large polluted sites such as
Conclusions and discussion
Lekkerkerk. Soil became an issue for further scientific exploration, beyond the scope
of agricultural goals, invoking new and large research programmes. The introduc-
tion of the principle of multifunctionality also helped to broaden the scope of what
was considered relevant scientific knowledge; the ecological function was identified
as the most vulnerable one, and therefore as the most restrictive to the determina-
tion of soil quality standards. Research into the effects of potentially toxic sub-
stances on the biotic part of ecosystems became more important in the second half
of the 1980s. Ecologists and ecotoxicologists were recruited as members of the
TCSP, who contributed to the development of standards in the second case study.
Remarkably, these ecologists and ecotoxicologists were almost exclusively concerned
with the effects of substances on soil fauna; research into the effects of potentially
toxic substances on plants was restricted to agricultural approaches, with a focus on
crop growth and to a lesser extent on the concentration of substances in edible plant
parts. Phytotoxicity (toxicity for plants) was a minor field of research, restricted to
a small group of researchers at the Amsterdam Free University (prof. W. Ernst).
Scientific knowledge labelled as usable knowledge in the second case study was eco-
toxicological and pertained to effects of substances on soil fauna.
As explained in Chapter 7, the scientific knowledge in the third case pertained
to a mixture of available scientific knowledge to determine the effects of substances
on soil and to classify land use. A variety of disciplines now is involved in the devel-
opment of standards. Approaches from spatial planning concerning the classifica-
tion of soil were added. Compared to the first case study, a completely new soil clas-
sification system was introduced, which was not based on chemical and physical
characteristics, but rather on different forms of land use and its requirements.
Geography and spatial planning became relevant fields of knowledge for the devel-
opment of the new framework of standards. The new classification of soil quality,
resulting from the introduction of the soil remediation objectives, illustrates that
soil had become an economic and societal resource, where it used to be an envi-
ronmental resource and compartment.
bw.souren 18-09-2006 15:47 Pagina 189
For the third research question (What are the arguments applied in labelling and
how do they relate to the dimensions of the institutional context? (Chapters 5, 6,
and 7)), the arguments applied in labelling knowledge in the three cases are brought
together in this section. 189
It was assumed in Chapter 3 that these arguments were related to the institution-
chapter 8
al context. As was concluded in Section 8.1.1, the first episode was characterised by
the concern for the development of the legal framework and for the position of soil
policy relative to other environmental fields. In the first case study, I searched for the
arguments used in labelling. In part the arguments used in labelling appeared as sci-
entific arguments; the two characteristics used to standardise soil quality (lutum and
organic matter) and the appropriate relation between these were subject of intense
debate. This debate was spelled out in the TCSP advice on the provisional reference
values (VTCB 1986a, 1986b). The argument for labelling the available knowledge as
usable knowledge was related to the urgency to proceed with the development of soil
policy. The sense of urgency to proceed with the development of soil policy was
caused by the ever-increasing number of polluted sites that were being discovered.
Scientists and policymakers were concerned with soil quality and were eager to pro-
tect soil quality. The concept of multifunctionality provided the cognitive concept
that united this effort. Although the meaning of the concept and the appropriateness
of the available knowledge to operationalise it was questioned by scientists and by
CRMH, it was not a decisive argument against labelling.
As was shown in Chapter 4, Section 4.1, the development of standards was con-
sidered an integrated part of a legal framework for soil quality in the first episode.
Standards were considered important instruments for the implementation of soil
protection as it had been formulated in the Preliminary Soil Policy Plan, awaiting
the Soil Protection Act (Min.V&M 1976b; Min.VROM 1983). Based on the
research described here, it could be concluded that the labelling of usable knowl-
edge in this first case study was related to the regulative dimension. If we look at
this labelling in detail as was done in Chapter 5, it is clear that labelling in this case
study was a matter of connecting available knowledge (the Edelman data) to the
requirements of a list of concentrations representing clean soil (see Chapter 5).
Labelling was not a matter of choosing between different bodies of available knowl-
edge, as was the case in the second and third case study; in this first case study there
was simply no alternative approach available.
In the second case study, there were several instances of labelling. A major
labelling process took place when the Health Council assessed a number of
approaches and labelled the Kooijman approach as the best because it was most
accurate. However, this advice was not followed as it turned out that the results
obtained by Kooijman were difficult to implement, and so the models by Van
bw.souren 18-09-2006 15:47 Pagina 190
Straalen and Denneman, that were based on assumptions and basic work by
Kooijman were used to calculate concentration levels. The coherence of policy con-
cepts and scientific concepts became important. Knowledge was usable if it facili-
tated the development of a concept based on both a policy and a scientific concept.
The arguments used in labelling were in part cognitive, as there was intense debate
190 about risk levels and the adequacy of using the composition of species as an indica-
tor of ecosystem functioning. Arguments were related to the cognitive dimension.
Conclusions and discussion
chapter 8
dards. In the second case study, scientific arguments were also used by the Health
Council. However, as shown in Chapter 6, these were not decisive. In none of the
cases, these (scientific) arguments were brought to the fore as the main, decisive,
and convincing arguments.
Figure 8.2 illustrates that science and policy are connected to each other. Although
this may sound trivial, it is not from a historical perspective. This connection was
actively established in the first episode. Before then soil policy as such was inexis-
tent and soil science, with its focus on nutrient and fertiliser, crop growth and pro-
duction, had a different focus. In the first episode, science and policy concerned
with soil quality began to develop relations beyond an informal status, and the
intense interactions between science and policy revealed that they both claimed a
position in the labelling of usable knowledge. Boundary work appears in this case
as boundary blurring; the boundary between science and policy partly disintegrates.
From that perspective, the establishment of the PTCSP was a landmark in that
episode. In the second episode regulatory science and research science were demar-
cated. The comparison of different scientific methods followed by labelling one of
them as usable. Through this comparison of existent methods, the labelling process
resulted in the active demarcation between regulatory science and research science.
In Figure 8.2, this demarcation is illustrated by the dotted line at the left part of the
overlapping area. In the third episode, the boundary between (regulatory) science
and policy was subject of intense debate between the RIVM and Core team A. This
debate refers to the dotted line at the right part of the overlapping area.
What was left untouched in this research was whether boundary work occurred
in the policy domain, i.e., was there any demarcation or blurring taking place with-
in policy distinguishing regulatory policy issues from other policy issues. From this
perspective boundary work in the three respective cases manifested itself as bound-
ary blurring and as boundary demarcation.
The research described here focused on the development of standards. In doing
so, the implementation of standards was forced to the edges of the scope of this the-
sis. By focusing on science and policy, other actors (industry, consumers, consul-
tancies, companies, media) where forced to the edges of the scope as well. This
restriction was productive for the most part, but became somewhat more problem-
atic in the analysis of the third case, where the development of new standards was
determined to a large extent by the actors involved in the implementation of the
standards, i.e., industry and the local authorieties. A case study conducted within
the framework of this thesis research by an MSc student on the development of the
bw.souren 18-09-2006 15:47 Pagina 193
concept of added risk (Van Langen 2001) made it clear that industry and private
parties were claiming a position at the table of standard setting. Future studies into
the development of standards should broaden up the perspective and include devel-
opment as well as implementation of standards more explicitly.
193
8.2 Labelling usable knowledge for soil quality standards in
chapter 8
the Netherlands
Now that the research questions have been treated and answered in Section 8.1, the
guiding question remains to be answered. In Chapter 1 the guiding question was
formulated as repeated here:
How can we understand the labelling of usable knowledge for the development of
soil quality standards in terms of boundary work between science and policy and in
terms of the relation between regulatory practice and its institutional context?
The answer to this guiding question is not straightforward, which is why I come back
to the perspectives explained in Chapter 1 to have guided the research described in
this thesis. In Chapter 1, it was explained that standards were perceived in this the-
sis as instruments between science and policy. In Section 1.3, it was argued that the
representation of the development of standards involving scheduled interaction
between the separable domains of science and policy was inappropriate. The assump-
tion that science and policy are separate domains in the development of soil quality
standards is problematic, and because of that, the idea of a scheduled interaction is
inappropriate. The domains of science and policy cannot be distinguished unam-
biguously as was shown by the analyses of the cases and the context in this thesis. The
perception that the responsibilities and tasks of science and policy are clear is not
supported by the research described in this thesis. Moreover, the case studies reveal
the opposite: the tasks and responsibilities are situation-specific and negotiated in
every specific case. Examples from each of the case studies in support of this claim
are given. In the first case study, policymakers at the Ministry of Public Health and
the Environment used scientific knowledge they had gained themselves to write a
first proposal for the reference values. It could be argued that the sense of urgency at
that moment legitimated the policymakers to publish a list with provisional reference
values. In a strict distinction of tasks and responsibilities between science and policy,
however, it would have to be the scientists who drew up a first proposal for concen-
tration levels indicating clean soil. In practice this distinction between tasks and
responsibilities was clearly and actively blurred. As an example from the second case
study, scientists developing the Van Straalen method to establish Maximum Tolerable
Risk levels argued that their scientific method would help to further soil policy. In
bw.souren 18-09-2006 15:47 Pagina 194
fact, this was their motivation for the development of the method, which they would
not have in a strict distinction of tasks and responsibilities. As an example from the
third case study, the distinction between science and policy was unclear; the tasks and
responsibilities for the land use typology, developed in that case study, shifted back
and forth between the National Institute for Public Health and the Environment and
194 the Ministry of Public Housing, Spatial Planning and the Environment. The tasks
were not clear beforehand, but developed in due course. These examples support the
Conclusions and discussion
claim that the assumed distinction between tasks and responsibilities of science and
policy is misleading and inadequate to further the understanding of the development
of soil quality standards. As a final example that is not specifically related to one of
the case studies, the results of a survey held at the National Symposium Bodembreed
are revealing (Souren 2000; Souren, Poppen et al. 2000). First, most of the respon-
dents (visitors of the Annual Symposium) were affiliated to policy and research
organisations either at the same time, or had changed job positions in the recent past
between typical research and policy organisations. This information about profes-
sional careers reveals that it is inappropriate and probably also unproductive to dif-
ferentiate between scientists and policymakers as two distinct professional careers.
Second, except for the universities and the Ministry of Public Housing, Spatial
Planning and the Environment, no other organisation actively involved in the devel-
opment of soil quality standards was perceived by the participants as an organisation
exclusively producing scientific knowledge or exclusively as a policy-making organi-
sation. Organisations involved in soil policy were typified at intermediate positions;
somewhere between science and policy. They did not fall into either of the two cat-
egories. The results of the case studies call for an alternative representation of the
development of standards. In this alternative conception it should be acknowledged
that the development of standards takes place in a regulatory practice where differ-
ent interests are weighed and negotiated per situation. This allows for more effective
evaluations and reflections on the course and future direction of soil policy, environ-
mental policy and the use of quality standards as policy instruments. A representa-
tion of actual practice would also reveal that standards are not only the outcome of
social processes, but also the determinants of social processes. Standards for soil qual-
ity also determine the playground for all parties with an interest in soil quality, rang-
ing from scientists, to policymakers, to industry, to home-owners, and other parties.
For instance, the height of the standards determines clean-up costs and the exact
location of housing and construction projects. This reorientation acknowledges the
performative role of standards; that they indeed set the playground and are the deter-
minants of social processes. Recognising that the development of standards for soil
quality takes place in a regulatory practice is expected to enrich and inspire the fur-
ther development of environmental quality standards. It opens up various possibili-
ties to discuss and debate how to deal with uncertainties as they are produced and
perceived by different parties.
bw.souren 18-09-2006 15:47 Pagina 195
The second aspect of the answer to the guiding question is a reflection on the
concealment of the production process of standards behind the quantitative formu-
lation of these standards (Section 1.2). Whereas this quantitative representation sug-
gests that standards for soil quality represent scientific certainty and consensus, the
analysis of the labelling of usable knowledge made in this thesis has produced sub-
stantial ‘contradictory evidence’. From all three cases, serious doubts can be raised 195
about the scientific underpinning of the concentration levels that are used to quan-
chapter 8
tify policy objectives. The question can be raised why these standards are formulat-
ed as concentration levels anyway. What is the relevance of distinguishing soil with a
copper concentration of 35 mg/kg dry soil from soil with a copper concentration of
37 mg/kg dry soil, especially if the uncertainties associated with the production of
that concentration level are not explained and communicated? The representation of
standards as concentration levels thus suggests scientific certainty and consensus. On
the basis of the research described in this thesis this assumption must be contested at
the very least. To add further weight to the answer, the analyses of the cases in this
thesis showed that the concentration levels are calculated in models and approaches
that have been selected based on arguments related to the institutional context of soil
policy and research. The quantitative representation conceals this background. The
arguments used in labelling and the political choices they represent, disappear behind
the concentration level. As it is, these arguments, through their relation to the
dimensions of the institutional context are much more informative about the course
of soil policy than the listings of concentration levels as such. From the analysis of
the case studies, it was observed that arguments related to the normative dimension
have become more important. This is to say that the quality standards have become
instruments in facilitating the complex interactions and interests of parties involved
in issues of soil quality. This background is concealed behind the listing of concen-
trations for substances. It is essential information for those actors participating in the
further development of soil policy and quality standards. The framework of soil qual-
ity standards has become prohibitively complex and is beyond the understanding of
many actors and the public.
In addition, a significant body of research has been accumulating over the past
years about the various problems associated with quantitative representation of what
is known to be fraught with scientific dissent and uncertainty (Hoffmann-Riem and
Wynne 2002; Klinke and Renn 2002; Walker et al 2003). In addition to the two
issues above (scientific dissent and uncertainty, and the political choices made in the
development process), trust in scientific expertise is at stake, and trust, after all, is
expected to benefit from a more open and reflexive attitude.
bw.souren 18-09-2006 15:47 Pagina 196
An interpretative approach opens up black boxes, not just for the sake of opening
up (although it is rewarding as such at times), but for the sake of understanding.
The box of labelling usable knowledge for soil quality standards was opened up in
196 this thesis. That was done by developing and applying an interpretative framework
to three case studies and their context. In the interpretative framework, boundary
Conclusions and discussion
work was taken as the initial perspective. The concept has been used by several
researchers in analyses of the relation between science and policy (Halfmann 2000;
Jasanoff 1990) and in analyses of standards and indicators (Bal 1998; Turnhout
2003). Based on an argumentation given in full in Chapter 3 and not repeated here,
the concept of institutional context was added to the interpretative framework as a
means to further understanding. What this approach has added to our insight is
that the arguments used in the labelling of usable knowledge relate to the context
within which these standards are developed and implemented. With the develop-
ment of this context, the argumentation changes.
The resulting interpretative framework also facilitated the comparison of cases
and context. The wider context within which standards for soil quality were devel-
oped and implemented was analysed and described in terms of the three dimensions
(cognitive, normative and regulative) and in each of the case studies the arguments
used in labelling could be evaluated for their relation to the institutional context. In
doing so a methodology for contextual analysis was developed.
Besides pointing out the advantages of applying the institutional perspective in
addition to the boundary work metaphor, it is important to discuss a drawback of
the concept of institutional context as developed by Scott. Analytically distinguish-
ing between normative, cognitive and regulatory dimensions in policy fields sug-
gests that distinctions can indeed be observed. This is not true, because it is the ana-
lyst who differentiates between these dimensions and who sorts the empirical mate-
rial. The advantage of an essentialist approach like this one, is that it helps to under-
stand and interpret the relation between regulatory practice and institutional con-
text, which is part of the guiding question of this thesis. Additional research would
have to focus on the interplay of the dimensions. Wherever I felt it was clear and
appropriate to do so, I pointed at instances where aspects of these dimensions inter-
acted. For instance replacing the principle of multifunctionality by a function-ori-
ented approach as discussed in Chapters 4 and 7, was not exclusively about a change
in the cognitive dimension. Rather, both concepts were paralleled by developments
on the normative dimension. For instance, the definition of the principle of multi-
functionality gives no indication whatsoever that national government has primacy
over provincial or municipal government. The concepts have become symbols refer-
ring also to the relations between science and policy and to the relations between
national and sub-national governments, more than to soil quality. These difficulties
bw.souren 18-09-2006 15:47 Pagina 197
in sorting out the empirical material are typical for essentialist approaches. Such
approaches are prone to criticism. Although criticised by many, essentialist typolo-
gies abound. A good essentialist typology forces the researcher to be explicit about
the arguments to sort out the empirical material into the typology. As I see it, the
concept of institutional context as developed by Scott does not yet qualify as a ‘good
essentialist typology’. As discussed in Chapter 3, the definition of the three dimen- 197
sions is not fully fledged, leaving too much degrees of freedom for any researcher to
chapter 8
sort out the empirical material.
An issue that should be explored further in the future is the consistency of the
two perspectives (boundary work and institutional context) with respect to their
epistemological assumptions. In general, institutional concepts assume a tension
between dynamics and stability. For instance, applying the concept of institutional
context forced me to search for patterns, stabilisations. That worked well, as long as
I did not get into the details of the development of standards for soil quality. As soon
as I did that, the assumed stability (sedimented regulatory practice) dissolved. The
boundary work perspective is almost the exact opposite: the name alone reveals a
focus on action, on activity, and on change. From a boundary work perspective, sta-
bility is an illusion. This tension between dynamics and stability was solved by
explaining the relation between the case studies and the context. In the context chap-
ter I searched for relatively stable patterns, while the case study allowed uncovering
daily work. In doing so, I managed to keep the tension between the different episte-
mological perspectives within limits, and even use this epistemological difference as
a means to increase insight and understanding of both the cases and the context.
bw.souren 18-09-2006 15:47 Pagina 198
bw.souren 18-09-2006 15:47 Pagina 199
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Appendix
205
Informants
Prof.dr. F.A.M. de Haan Wageningen University
Prof.dr. P. de Ruiter SKB
Prof.dr. H.J.P. Eijsackers Alterra
Dr. J. Faber Alterra
Dr. J. Hermens Utrecht University
Mrs. drs. M. Klein IKC Wageningen
Mrs. dr. Ch. Klok Alterra
Prof.dr J. Koeman Wageningen University
Drs. S. Ouboter NOK
Mrs. dr. J. van Wensem TCSP
Respondents
Mrs. dr. S. Boekhold VROM March 5, 2002
Drs. N. de Wit VROM October 24, 2002
Drs. Th. Edelman Wageningen University April 5, 2000
Prof. dr. H.J.P. Eijsackers Alterra March 5, 2002
Prof. dr. S.A.L.M. Kooijman Free University February 21, 2002
Dr. Th. Lexmond Wageningen University April 6, 2000
Drs. J.E.T. Moen Consultancy July 31, 2000
Dr. J. Lijzen RIVM January 21, 2003
Prof. dr. W.C.Reij (retired) Voorschoten June, 24, 2002
Prof. dr. N.M. van Straalen Free University March 27, 2002
Dr. J. Vegter TCSP May 2, 2000
Ir. D. Zeilmaker (retired) Harlingen October 9, 2001
bw.souren 18-09-2006 15:47 Pagina 206
bw.souren 18-09-2006 15:47 Pagina 207
Summary
207
Standards, soil, science and policy
Labelling usable knowledge for soil quality standards
in the Netherlands 1971-2000
Standards for soil quality distinguish between ‘polluted soil’ and ‘clean soil’. That
distinction is formulated as a concentration level specific for a substance. For exam-
ple, the soil quality standard for copper published in 1988, stated that standard soil
(soil with a specific lutum and organic matter content) with a copper concentration
of 35 mg per kg dry soil, or lower, is classified as ‘clean’, whereas soil with a copper
concentration of 36 mg per kg dry soil or higher is classified as ‘polluted’. For most
substances such concentration levels have been derived over the years. Classifying a
soil as polluted, has far reaching implications. For instance, sites that are classified
as ‘polluted’ have to be cleaned-up. Clean-up treatments are often time consuming
and expensive. Well known examples in the recent history of Dutch soil policy are
the extensive treatment projects at the Volgermeerpolder, the Utrecht Griftpark and
a residential area in Lekkerkerk. Because of the far reaching implications, the exact
level of the standards is of interest to all parties involved. Not surprisingly, these dif-
ferent parties want to have a say in the development of the standards. Traditionally,
science and policy dominated this development, but more recently other parties like
industry, and local and regional authorities have become increasingly important.
The scientific underpinning of standards is still considered crucial, but the number
of stakeholders involved made the process of standard development more compli-
cated (and more interesting).
The development of standards for soil quality in the Netherlands between 1971 and
2000 is the broad subject of this thesis. More specifically, it is the process of selec-
tion of specific scientific models and approaches to calculate the concentration lev-
els that is analysed in this thesis. Soil quality standards have been developed in
Dutch policy since the early 1980s. In 1982 the first standards, the so-called ABC
values, were published. Since then soil quality standards have been updated regu-
larly. Sometimes updates stemmed from new scientific insights, but mostly it were
bw.souren 18-09-2006 15:47 Pagina 208
policy developments that were the main drivers for the formulation of a new set of
standards. In 1988, 1991/1994 and 1999, the ABC values were succeeded by the
reference values, target/intervention values, and soil remediation objectives respec-
tively. Changes in the height of the standards or in the policy measures following
standard violation can cause great confusion, and maybe even generate distrust in
208 the standards and the standardsetting process. However, changes can also be per-
ceived as a relief. For instance when parties agree that standards are too strict, relax-
Summary
ation of the standards is welcomed. For standards to be trusted and accepted among
involved parties they have to be tuned to the context in which they are used and
developed. Standards must not only be scientifically underpinned, but they must
also fit in the context of the involved parties and their interests.
This broader context is concealed when standards are viewed only as substance
specific concentration levels. The research project described in this thesis, aims to
remove this concealment. At least a part of it is unveiled by looking at the process
of how knowledge is labelled as usable to derive concentration levels. In this process
science and policy are both involved.
Having said this, a qualification is in place. The mere suggestion that science and
policy could be distinguished as distinct parties in the development of standards has
been criticised repeatedly. The practice of standards’ development is more accurately
represented as a process in which science and policy meet and merge, up to a level
where they cannot be distinguished unambiguously. For instance, representatives from
the responsible ministries and staff from research institutes are both involved. In most
cases these people have an academic background in a relevant discipline. The argu-
ments used in labelling knowledge as usable contain scientific, as well as policy, argu-
ments and interests. In this thesis these arguments are traced down and analysed with
the help of an interpretative framework that will be explained below. Before moving
on to this explanation one more characteristic of standards must be mentioned.
So far, standards have been framed to represent a physical quality, the concen-
tration level of a substance in the soil. However, its implications are of a socially
constructed nature: what is clean or polluted is not a physical quality itself; it is a
value judgment and the outcome of a social process. The hybrid character makes
standards an interesting object of study. To understand the hybrid character of stan-
dards one needs to be familiar with both the physical and social aspects of standards.
This thesis represents an interdisciplinary study that draws attention to and expos-
es the hybrid character of soil quality standards.
As argued above, science and policy are both involved in the production of stan-
dards; each with its own perspective, but with the common interest to develop stan-
dards. In this thesis the joint involvement of science and policy is characterised as
‘regulatory practice’. One of the processes ongoing in regulatory practice is the
labelling of usable knowledge to calculate concentration levels that eventually get
the status of standards for soil quality. What models are used to calculate these lev-
els? What approaches are adequate to decide whether adverse effects of the presence
bw.souren 18-09-2006 15:47 Pagina 209
Summary
ing and relevant to understand the knowledge labelling process in regulatory prac-
tices. There are several possible approaches to achieve this aim. In this thesis it was
assumed that the arguments used for the labelling of usable knowledge are indeed
related to the context within these standards for soil quality are embedded: the con-
text of soil policy. As was mentioned above, for standards to be trusted and accept-
ed, they have to be tuned to the context within which they are used and developed.
The main concepts used in this research to analyse the development of standards are
‘boundary work’, as coined by T.F. Gieryn in 1983, and ‘institutional context’, pro-
posed by W.R. Scott since 1995.
The first concept, boundary work, refers to the interaction between science and
policy in which the boundary between the two domains is at stake. Boundaries
between science and policy can be blurred, (re)produced, penetrated, crossed, etcetera.
I looked at the labelling of usable knowledge from that perspective. The differences or
similarity between science and policy is central to such a perspective. The concept of
boundary work is attractive when describing processes related to the utilisation of sci-
entific knowledge in policy and regulatory issues, and it has been widely used for that
purpose. However, I found that the concept had insufficient analytical strength for the
purpose of this thesis. The application of an institutional perspective, complementa-
ry to boundary work, was found to enhance understanding of the processes studied in
this thesis. This is reflected in the guiding question mentioned below, in which both
concepts (boundary work and institutional context) are included. The concept of
institutional context makes explicit and operational that institutions are multidimen-
sional; a regulative, normative and cognitive dimension are distinguished. The regu-
lative dimension is characterised with the indicators rules, laws and sanctions. It has
expedience as its basis of compliance and coercive mechanisms. Applied to the
labelling of usable knowledge, arguments based on references to legal frameworks
would qualify as regulative. The normative dimension defines goals or objectives (e.g.
winning the game, making a profit) but also designates appropriate ways to pursue
them (e.g. rules specifying how the game is to be played, conceptions of fair business
practice). Some values and norms apply to all actors involved, whereas others apply
only to certain types of actors or positions. The latter gives rise to roles: conceptions
of appropriate goals and activities for particular individuals or specified social posi-
tions. The cognitive dimension refers to shared conceptions that constitute the nature
of social reality and the frames through which meaning is generated.
bw.souren 18-09-2006 15:47 Pagina 210
Central question
The guiding question of this thesis includes both concepts as complementary per-
spectives for the understanding of labelling usable knowledge:
210 How can we understand the labelling of usable knowledge for the development of
soil quality standards in terms of boundary work between science and policy and in
Summary
terms of the relation between regulatory practice and its institutional context?
The guiding question is broken down in five separate research questions. These
questions are addressed in the empirical chapters that are at the heart of the thesis.
The three dimensions were used to describe the context of soil policy and the devel-
opment of scientific knowledge (Chapter 4). Writing a concise history of a policy
field and the development of scientific knowledge is prone to criticism from insid-
ers as such overviews are never exhaustive. The aim was to provide an interpretation
of recent history for the purpose of my study: to better understand the arguments
that are used in labelling usable knowledge for soil quality standards and to under-
stand how regulatory practice and institutional context are linked. A second and
more critical issue could be brought up, concerning the method applied to analyse
and describe the institutional context. I sorted out all material by using the three
dimensions as described above. While doing so, it became clear that several events,
achievements and developments could be assigned to more than one dimension. It
must be noted that it cannot be objectively established whether a particular event,
achievement or development should be classified as cognitive, normative or regula-
tive. For instance, cognitive concepts (cognitive dimension) are developed through
interaction between actors (normative dimension). As it is, the cognitive and nor-
mative dimensions are closely related. The same holds for the regulative and nor-
mative dimension. Acts and rules (regulative dimension) are developed and main-
tained in the interaction between actors (normative dimension). Because of this
interrelatedness, the cognitive, normative and regulative dimensions cannot be dis-
tinguished unambiguously. The rationale for the distinction made during this
research was that events, achievements and developments that were mentioned or
bw.souren 18-09-2006 15:47 Pagina 211
used in interviews and documents as important for the relations between different
actors, were grouped as normative. Other events, achievements and developments
were interpreted either as regulative or cognitive. The context was subdivided into
three episodes and each episode was characterised by identifying regulative, cogni-
tive and normative events, achievements and developments.
211
Episode 1; 1971-1988 Episode 2; 1989-1994 Episode 3; 1995-2000
Summary
Regulative • Interim Soil Pollution Act • Integration of Interim Soil • Revision Soil Protection
(1983) Pollution Act and Soil Act (1994)
• Soil Protection Act (1987) Protection Act (1994) • Cabinet’s position (1997)
• Building Materials Decree
(1999)
Cognitive • Multifunctionality • Risk approach • Function-based quality
• Multifunctionality • Risk approach
• Multifunctionality
Normative • Carving out a department • Active soil management • Active soil management
(sector) for soil quality at the • Increase in number of actors • Soil policy renewal:
Ministry of Public Health involved in policy development BEVER, six aspects from
and the Environment (notably the VNG, the IPO) Target Perspective
• Disputes between ministries • Integration of environmental • Soil research programmes
over authority to regulate policy fields (PGBO, NOBIS, SKB)
soil quality • Criticism with regard to
• Establishing the Technical abstract and insufficiently
Committee on Soil operational principles guiding
Protection soil policy
• Soil research programmes • Soil research programme
(Soil Protection, Soil (Netherlands Integrated Soil
Ecology, Netherlands Research Programme SPBO)
Integrated Soil Research
Programme SPBO)
The case studies described in this thesis are embedded within the context of a series
of episodes. The first episode (1971 -1988) contains a case study on the labelling of
usable knowledge for the reference values. The second episode starts in 1989 and ends
in 1994. In this second episode, the second case study pertaining to labelling of usable
knowledge for target and intervention values is embedded. The third and last episode
starts in 1995 and ends in 2000. The third case study is embedded in this episode and
pertains to the labelling of usable knowledge for soil remediation objectives.
In each of the three case studies, I searched for the arguments that were used in
labelling and considered the connections between these arguments and the dimen-
bw.souren 18-09-2006 15:47 Pagina 212
sions of the institutional context. In fact by doing so, it revealed the connection
between the processes ongoing in the case study (labelling of usable knowledge in
regulatory practice) and the institutional context that each of the case studies was
embedded in. For each of the case studies that link was clarified, and in addition the
differences in the arguments for the labelling of usable knowledge between the three
212 case studies could be highlighted.
Summary
In the first case study I analysed the labelling of usable knowledge for the development
of reference values for heavy metals. Labelling in that case was a matter of justifying
the adequacy of available knowledge to calculate reference values, thereby satisfying
the need for standards. Policymakers and scientists were concerned with the slow
progress of soil policy and the lack of adequate soil quality standards to further poli-
cy development. In fact, the guiding principle for soil policy had been formulated, but
an operationalisation of it was still lacking. The reference values were meant to do just
that. This guiding principle; multifunctionality, stated that the quality of soil had to
be such that it qualified for all land uses. It was assumed that soil quality in relatively
undisturbed areas met that criterion and consequently, the concentrations of heavy
metals in those areas were used to calculate these reference values.
In the second case study, results of experimental studies measuring the effects of
substances on specific soil organisms, were used to calculate the new soil quality
standards. The scientific knowledge that was labelled as usable was experimental
ecotoxicological knowledge. Compared to the previous case, the importance of
eco(toxico)logical knowledge relative to soil science had increased. That knowledge
was tuned with the development of the risk approach in Dutch environmental pol-
icy. The risk approach was introduced in Dutch environmental policy in 1989. In
soil policy, the risk approach complemented the principle of multifunctionality.
In the third case study, the situation had changed. The principle of multifunc-
tionality that had been central to soil policy was abandoned when evaluating pol-
luted sites. It was replaced by the principle of function-based quality. This principle
implied that soil quality criteria had to be derived for different land uses. These soil
quality criteria (soil remediation objectives) were developed within a policy renew-
al project (BEVER). This policy renewal aimed at decentralisation and at the
increase of a participatory approach in soil policy. The development of the soil
remediation objectives was analysed in the third case study. The knowledge that was
labelled as usable had been developed and applied before for other soil quality cri-
teria that where used in a different context (agriculture, spatial planning).
bw.souren 18-09-2006 15:47 Pagina 213
The study described in this thesis revealed that the arguments that are used for the
labelling of usable knowledge for soil quality standards were related to the institu-
tional context of soil policy and the development of scientific knowledge on soil
quality. In the first case the progress of soil policy, especially the implementation of 213
the Soil Protection Act, provided a crucial argument in the labelling process. That
Summary
is to say that the regulative dimension played an important role in the labelling of
usable knowledge. For the second case study it could be argued that the cognitive
dimension became most important. The risk approach had been formulated in close
cooperation with scientists and it stated that minimum risk levels for environmen-
tal compartments were inevitable and that they had to be identified at concentra-
tion levels below which 95% of the species in an ecosystem were not exposed above
an adverse concentration level. Specific models, based on experimental ecotoxico-
logical knowledge were applied to estimate these levels. Finally, in the third case
study, standards had to be developed to facilitate a renewal in soil policy that
focused on decentralisation, involvement of stakeholders and integration with other
policy fields. The involvement of different actors, interests and approaches was
reflected in the knowledge that was used to develop the soil remediation objectives.
This knowledge was developed and used by different actors and was applied in agri-
cultural and spatial planning policy.
The representation of standards as concentration levels suggests scientific cer-
tainty and consensus. On the basis of the research described in this thesis this
assumption must be contested at the very least. The analyses of the cases in this the-
sis showed that the concentration levels are calculated in models and approaches
that have been selected based on arguments related to the institutional context of
both soil policy and research. This adds further weight against the above assump-
tion. The arguments used in labelling and the political choices they represent, are
concealed behind the concentration level. As it is, these arguments, through their
relation to the dimensions of the institutional context are much more informative
about the course of soil policy than the listings of concentration levels as such. From
the analysis of the case studies, it was observed that arguments related to the nor-
mative dimension have become more important over the years. This is to say that
quality standards have become instruments to facilitate the complex interactions
and interests of parties involved in issues of soil quality. This background is essen-
tial information for actors participating in the further development of soil policy
and quality standards. The framework of soil quality standards has become very
complex and is beyond the understanding of many actors and the public.
In addition, a significant body of research has been accumulating over the past
years about the various problems associated with quantitative representation of what
is known to be fraught with scientific dissent and uncertainty. In addition to the
bw.souren 18-09-2006 15:47 Pagina 214
two issues above (scientific dissent and uncertainty, and the political choices made
in the development process), trust in scientific expertise is at stake, and is expected
to benefit from a more open and reflexive attitude.
In the last chapter of the thesis a reflection on the approach and theoretical choices
is given. An interpretative approach opens up black boxes. That was done in this
thesis by developing and applying an interpretative framework to three cases and
their context. In the interpretative framework, boundary work was taken as the ini-
tial perspective. The concept has been used by several researchers in analyses of the
relation between science and policy. Besides pointing out the advantages of apply-
ing the institutional perspective in addition to the boundary work metaphor, it is
important to mention a drawback of the concept of institutional context as devel-
oped by Scott and applied in this thesis. Analytically distinguishing between nor-
mative, cognitive and regulatory dimensions in policy fields suggests that distinc-
tions can indeed be observed. This is not true, because it is the analyst who differ-
entiates between these dimensions and who sorts the empirical material. The advan-
tage of an essentialist approach like this one, is that it helps to understand and inter-
pret the relation between regulatory practice and institutional context, which is part
of the guiding question of this thesis. Additional research would have to focus on
the interplay between the dimensions. These difficulties in sorting out the empiri-
cal material, are typical for essentialist approaches. Although criticised by many,
essentialist typologies dominate the scientific field. A good essentialist typology
forces the researcher to be explicit about the arguments to sort out the empirical
material into the typology. As I see it, the concept of institutional context as devel-
oped by Scott does not yet qualify as a ‘good essentialist typology’. As discussed in
Chapter 3, the definition of the three dimensions is not full-fledged, leaving too
many degrees of freedom for any researcher to sort out the empirical material. A sec-
ond and related issue that should be explored further in the future is the consisten-
cy of the two perspectives (boundary work and institutional context) with respect
to their epistemological assumptions. In general, institutional concepts assume a
tension between dynamics and stability. For instance, applying the concept of insti-
tutional context forced me to search for patterns and stabilisation. That worked
well, as long as I did not get into the details of the development of standards for soil
quality. As soon as that happened, the assumed stability (crystallized regulatory
practice) dissolved. The boundary work perspective is almost opposite: the name
alone reveals a focus on action, activity and change. From a boundary work per-
spective, stability is an illusion. In this thesis, the tension between dynamics and sta-
bility was solved by explaining the relation between the case studies and the con-
bw.souren 18-09-2006 15:47 Pagina 215
text. In the context chapter relatively stable patterns were searched for, while the
case study allowed uncovering daily work. In doing so, I managed to keep the ten-
sion between the different epistemological perspectives within limits, and even use
this epistemological difference as a means to increase insight and understanding of
both the cases and the context.
215
Summary
bw.souren 18-09-2006 15:47 Pagina 216
bw.souren 18-09-2006 15:47 Pagina 217
Samenvatting
217
Normen, bodem, wetenschap en beleid
De selectie van bruikbare kennis voor de afleiding
van bodemkwaliteitsnormen in Nederland 1971-2000
aanleiding vormden voor vernieuwing van de normen. Die vernieuwing leidde ach-
tereenvolgens tot de vaststelling van de referentiewaarden in 1988, de streef- en
interventiewaarden in 1991/1994 en de vaststelling van de bodemgebruikswaarden
in 1999. Steeds was de aandacht voor de wetenschappelijke onderbouwing groot en
steeds weer werd die wetenschappelijke onderbouwing uitvoerig beschreven en
benadrukt.
Elke verandering in de normen en in de beleidsmaatregelen die verbonden zijn
aan overschrijding van de normen, heeft vergaande gevolgen. Het kan leiden tot
maatschappelijke onrust, en als die veranderingen elkaar snel opvolgen kan het lei-
den tot afnemend vertrouwen in de normen en in het normstellingsproces als zoda-
nig. Gezien de waarde die gehecht wordt aan de wetenschappelijke onderbouwing,
staat ook het vertrouwen in de wetenschap op het spel. Toch ook kan aanpassing
van de normen verwelkomd worden, bijvoorbeeld wanneer de actoren de bestaan-
de normen als beperkend of te strikt beoordelen. Daarmee wordt duidelijk dat de
acceptatie van en het vertrouwen in normen en normstelling van meerdere factoren
afhangt. Er moet afstemming plaatsvinden tussen de hoogte van de norm, de
beleidspraktijk en het wetenschappelijke onderzoek. In het proefschrift maak ik die
afstemming zichtbaar en komt de betrokkenheid van wetenschap en beleid aan de
orde. Daarmee is niet gezegd dat ik wetenschap en beleid als afzonderlijke domei-
nen opvat. Het onderscheid tussen wetenschap en beleid is niet eenduidig. Er is
sprake van een normstellingspraktijk. Die praktijk wordt gekenmerkt door het
gedeelde belang van wetenschap en beleid bij de vaststelling van normen.
De wetenschappelijke onderbouwing van normen bestaat doorgaans uit com-
plexe modellen. Die zijn gebaseerd op resultaten van metingen van de concentraties
van stoffen in de bodem en van experimenten waarbij organismen worden blootge-
steld aan potentieel toxische stoffen. De personen die betrokken zijn bij besluitvor-
ming over die wetenschappelijke onderbouwing hebben vaak een wetenschappelij-
ke opleiding in een relevant vakgebied en hebben redelijk tot goed in zicht in die
modellen. Dat geldt voor degenen die verbonden zijn aan een universiteit of onder-
zoeksinstituut, maar ook voor beleidsmakers. Omgekeerd zijn de betrokken mede-
werkers van universiteit of onderzoeksinstituut op hun beurt goed geïnformeerd
over het beleid. In de besluitvorming worden beleidsmatige en wetenschappelijke
argumenten voor de selectie van bruikbare kennis in samenhang gebruikt.
In het bovengaande is de nadruk gelegd op normen als representaties van een
bw.souren 18-09-2006 15:47 Pagina 219
fysiek kenmerk van de bodem: het concentratieniveau van een stof in de bodem.
Echter, de betekenis van die norm: ‘schoon’ of ‘verontreinigd’, is een sociaal con-
struct. De kwalificaties, ‘schoon’ en ‘verontreinigd’ zijn gebaseerd op interpretaties
van en waardeoordelen over de aanwezigheid van stoffen in de bodem. Ze liggen
niet als zodanig besloten in die aanwezigheid van de stoffen in de bodem. De norm
verwijst niet alleen maar naar een stofconcentratie. De norm verwijst ook naar de 219
uitkomst van een sociaal proces, waarin ‘schoon’ en ‘verontreinigd’ betekenis krij-
Samenvatting
gen. In het onderzoek naar normen spelen die twee representaties voortdurend met
elkaar. Voor de bestudering van normen is het van belang beide representaties in de
analyse te betrekken.
De veronderstelling dat de wetenschap alleen uitspraken doet over die fysieke
kenmerken, de stofconcentratie, en dat beleid gaat over die sociale constructie is nog
algemeen gangbaar. De resultaten van het onderzoek zoals beschreven in het proef-
schrift laten zien dat het van belang is die voorstelling van zaken waarin wetenschap
de fysieke representatie voor haar rekening neemt, en zich niet inlaat met norma-
tieve uitspraken en de classificatie van ‘schoon’ en ‘verontreinigd’ kritisch te bevra-
gen. Als gezegd, wetenschap en beleid zijn beide betrokken bij de afleiding van nor-
men en de selectie van de bruikbare, wetenschappelijke kennis. Ze doen dat beide
deels vanuit een eigen en verschillend perspectief, maar met het gedeelde belang bij
de vaststelling van de normen. In dit onderzoek behandel ik die samenwerking voor
de totstandkoming van normen als co-productie. Die co-productie vindt plaats in
een normstellingspraktijk. Een van de processen binnen die normstellingspraktijk is
de selectie van bruikbare wetenschappelijke kennis. Welk model wordt gebruikt om
de effecten van stoffen op ecosystemen en mensen te beschrijven en te voorspellen?
Op basis van welke wetenschappelijke kennis wordt het niveau vastgesteld waarvan
de risico’s als acceptabel kunnen worden aangemerkt? Deze vragen raken aan de
kern van milieubeleid en -management.
centraal staat. Het is dan ook een veelgebruikt concept in analyses van normstel-
lingspraktijken. Echter, als instrument voor analyse vond ik het voor mijn onder-
zoek niet toereikend. Om die reden heb ik het interpretatief kader uitgebreid met
een institutioneel perspectief: ‘institutionele context’. Dit concept is gebaseerd op
een review van institutionele benaderingen van W.R. Scott uit 1995. Het concept
vestigt de aandacht op het multidimensionale karakter van institutionele contexten.
Scott onderscheidt een regulatieve, cognitieve en normatieve dimensie, die in
samenhang de institutionele context karakteriseren. De regulatieve dimensie omvat
wet- en regelgeving. Toegepast op het onderwerp van het proefschrift vallen daar-
onder bijvoorbeeld de Interimwet Bodemsanering uit 1982 en de Wet Bodem-
bescherming uit 1987. Later komt daar onder andere het Bouwstoffenbesluit bij.
Doelmatigheid is een belangrijk uitgangspunt en handhaving en sanctionering zijn
belangrijke mechanismen in die regulatieve dimensie. De tweede, normatieve
dimensie, verwijst naar het spel en de spelregels die partijen hanteren om een
bepaald doel te bereiken. Als voorbeeld noem ik hier de ontwikkeling in de relatie
tussen de nationale en de gemeentelijke overheden. In het kader van de decentrali-
satie in het milieubeleid begin jaren negentig krijgt de gemeentelijk overheid meer
bevoegdheden en verantwoordelijkheden. Parallel aan die ontwikkelingen neemt de
invloed van industrie en maatschappelijke organisaties op de koers van het bodem-
beleid toe. De normatieve dimensie verwijst naar dergelijk ontwikkelingen.
Tenslotte, de derde cognitieve dimensie. Die dimensie omvat de betekenissen die in
het beleidsveld worden gegeven en de veranderingen daarin. Een voorbeeld daarvan
is dat bodem in de jaren zeventig vooral werd gezien als productiefactor voor de
landbouw, als ondergrond voor constructiewerken als bruggen en dijken, en als
stortplaats voor huisafval. In de jaren tachtig veranderde die visie en werd bodem
ook een beschermwaardig milieucomponent. Aan die laatste betekenisgeving heeft
het begrip ‘multifunctionaliteit van de bodem’ een belangrijke impuls gegeven. Dat
begrip hield in dat bodemkwaliteit ongeacht het actuele landgebruik van een zoda-
nig goede kwaliteit moest zijn zodat het voor elke functie geschikt zou zijn.
bw.souren 18-09-2006 15:47 Pagina 221
Centrale vraagstelling
Samenvatting
Deze centrale vraag is uiteengelegd in vijf onderzoeksvragen die in het empirische
deel van het proefschrift worden behandeld.
waarden gebruikt konden worden als normen voor goede bodemkwaliteit. Om ver-
gelijkingen mogelijk te maken tussen de verschillende bodemtypen in Nederland
(zand, veen, klei) werden de referentiewaarden gestandaardiseerd. Bodem van een
bepaalde samenstelling (lutum en organisch stofgehalte) werd als standaardbodem
aangemerkt. De referentiewaarde van 35 mg/kg droge grond voor koper had betrek-
king op die standaardgrond en kon met stofspecifieke correctieformule worden 223
omgezet naar een concentratieniveau voor grond van elke andere samenstelling. De
Samenvatting
verwijzing naar de ontwikkeling van de wetgeving speelde in deze case een belang-
rijke rol.
In de tweede case was het experimentele ecotoxicologische kennis die werd gebruikt
voor de afleiding van een nieuw stelsels van normen: de streef- en interventiewaar-
den. Sinds de afleiding van de referentiewaarden in de jaren tachtig was de kennis
over de effecten van blootstelling op organismen en ecosystemen sterk gegroeid. De
opkomst van experimentele eco(toxico)logie vanaf de tweede helft van de jaren tach-
tig leidde tot een grote hoeveelheid gevens over effecten van stoffen. Daarmee kon-
den dosis-respons relaties worden vastgesteld en kon de aanname die in de vorige
case zo bepalend was, getoetst worden. In samenhang met de ontwikkeling van
experimentele studies en het beschikbaar komen van grote hoeveelheden gegevens
werden modellen en statistische technieken ontwikkeld voor de ordening en inter-
pretatie van die gegevens. Met name extrapolatiemodellen en ecosysteemmodellen
dateren uit die tijd. De ontwikkeling in de wetenschappelijke kennis speelde een
belangrijke rol. Belangrijker was dat die kennis was ontwikkeld in afstemming met
de beleidsvisie. Als aanhangsel bij het Nationaal Milieubeleidsplan uit 1989 werd
door het Ministerie van VROM de brochure: Omgaan met risico’s gepubliceerd.
Daarmee werd de risicobenadering in het Nederlands milieubeleid geïntroduceerd
en werd geargumenteerd dat milieueffecten van stoffen als zodanig onvermijdelijk
waren. Het was zaak vast te stellen welke effecten acceptabel waren. Oftewel, welk
risico was acceptabel? De vaststelling van dat risiconiveau moest wetenschappelijk
onderbouwd worden.
Het beleidsdenken in termen van risico’s en acceptatie van effecten sloot goed
aan bij de verdere ontwikkeling van wetenschappelijke modellen waarmee voor
afzonderlijke stoffen afgeleid kon worden welk percentage van soorten in een eco-
systeem effect zou ondervinden van de aanwezigheid van die stof. Op basis van die
modellen werd het acceptabel (maximaal toegestaan) risiconiveau afgeleid van de
gemodelleerde concentratie waarbij 95% van de soorten geen als nadelige te waar-
deren effect zou ondervinden. Dit werd de streefwaarde. Een tweede norm, de inter-
ventiewaarde, werd uit dezelfde modellen afgeleid. Daarvoor werd het concentra-
bw.souren 18-09-2006 15:47 Pagina 224
tieniveau gebruikt waarbij 50% van de soorten geen nadelig effect ondervond. De
ontwikkeling van dit stelsel van streef- en interventiewaarden als uitwerking van de
risicobenadering in het Nederlands milieubeleid is een goed voorbeeld van wat in
de literatuur wordt geduid als ‘co-productie’. Wetenschappelijke ontwikkelingen en
beleidsontwikkelingen zijn daarin verweven en niet meer te duiden als simpele oor-
224 zaak-gevolg relaties. Behalve de verweving van wetenschap en beleid, levert de twee-
de case study ook een mooi voorbeeld op van het onderscheid tussen ‘research scien-
Samenvatting
ce’ en ‘regulatory science’. Het is onjuist om die termen te vertalen met ‘funda-
menteel onderzoek’ en ‘toegepast onderzoek’. Het onderscheid tussen ‘regulatory
science’ en ‘research science’ verwijst naar het complex van motieven van weten-
schappers om hun expertise al dan niet, of onder bepaalde condities, af te stemmen
met beleidsontwikkelingen die regulerend van aard zijn. De selectie van bruikbare
kennis in de tweede case is (ook) te duiden als het demarkeren van ‘regulatory scien-
ce’ en ‘research science’. Het principe van multifunctionaliteit bleef onverminderd
van kracht, waarmee er twee beleidsuitgangspunten naast elkaar bestonden, die
sterk van elkaar verschilden in de mate van operationalisering. Het principe van
multifunctionaliteit werd wel steeds luider bekritiseerd en in verband gebracht met
de maar toenemende omvang van de bodemsaneringsoperatie en de trage voortgang
in de sanering.
In de derde case staat de selectie van bruikbare kennis voor de afleiding van de
bodemgebruikswaarden centraal. Die bodemgebruikswaarden zijn afgeleid als
onderdeel van een vernieuwing van het bodembeleid (BEVER). Het principe van
multifunctionaliteit dat zo bepalend was geweest voor de ontwikkeling van het
bodembeleid werd ten dele vervangen door een functiegerichte benadering van
bodemkwaliteit en saneringen. Landgebruik werd daarmee bepalend voor de
bodemkwaliteit ter plekke. Voor de ontwikkeling van die bodemgebruikswaarden
was het allereerst nodig een classificatie te maken van landgebruik. Daarbij werd
gebruik gemaakt van classificaties uit de ruimtelijke ordening. Voor elk type land-
gebruik werden bijbehorende normen afgeleid; de bodemgebruikswaarden. De
bodemgebruikswaarden geven aan wat de minimaal vereiste bodemkwaliteit is voor
dat landgebruik. Wanneer die minimale bodemkwaliteit niet wordt gehaald moet de
bodemkwaliteit verbeterd worden. Dat kan bijvoorbeeld door te saneren, maar ook
door een zogenaamde leeflaag aan te brengen. Dat is een laag grond die aan die
minimale kwaliteit voldoet. Vergeleken met de referentiewaarden en de streefwaar-
den, zijn de bodemgebruikswaarden geen indicatoren voor ‘schoon’ maar voor een
minimaal vereiste bodemkwaliteit behorend bij een specifiek landgebruik.
De ontwikkeling van deze functiegerichte benadering kwam voort uit de kritiek
bw.souren 18-09-2006 15:47 Pagina 225
op het bodembeleid tot dan toe. Die kritiek werd met name door de gemeentelijk
en provinciale overheden en het bedrijfsleven geuit. De kern van die kritiek was dat
het bodembeleid en de bodemkwaliteitsnormen niet goed waren afgestemd op de
praktijk en dat ze te streng waren. Ook vanuit de nationale overheid werd aange-
drongen op versnelling van de bodemsaneringsoperatie. De hoeveelheid lokaties
waar gesaneerd moest worden en de daarmee gemoeide kosten waren niet langer op 225
te brengen. Er moest een meer pragmatische en praktijkgerichte koers worden geva-
Samenvatting
ren en die werd gevonden in de functiegerichte benadering. Daarmee raakte het
bodembeleid in de eerste helft van de jaren negentig verder verweven met het ruim-
telijke ordeningsbeleid, en met het natuur- en landbouwbeleid. Daarmee samen-
hangend ontwikkelde de betekenis van bodem zich van beschermwaardig milieu-
compartiment in de richting van een economisch te waarderen goed. De als bruik-
baar geselecteerde wetenschappelijke kennis bestond uit een verzameling van inzich-
ten en modellen afkomstig uit milieu-, landbouw- en ruimtelijke ordeningsbeleid.
De case studies hebben laten zien dat de argumentatie voor de selectie van bruik-
bare kennis verbonden is met de institutionele context. De argumentatie heeft niet
alleen betrekking op de wetenschappelijke kwaliteit van de betreffende kennis. In de
eerste case was de voortgang van het bodembeleid en de wet- en regelgeving een cru-
ciale factor in het proces van selectie. Uit de case study kan geconcludeerd worden
dat de regulatieve dimensie in die eerste episode van doorslaggevende betekenis is
geweest. Uit de tweede case study kan geconcludeerd worden dat de cognitieve
dimensie belangrijker wordt. De ontwikkeling van de risicobenadering en de ont-
wikkeling van wetenschappelijke kennis versterken elkaar. Dat leidt er toe dat die
kennis die het meest nauw verweven is met de risicobenadering, wordt geselecteerd
als bruikbaar. Uit de derde case study kan geconcludeerd worden dat de bodemge-
bruikswaarden onderdeel zijn van de ontwikkelingen in de relatie tussen partijen.
Daarmee is gezegd dat uit de derde case study de normatieve dimensie naar voren
komt als bepalend voor de selectie van bruikbare kennis.
De kwantitatieve voorstelling van normen voor bodemkwaliteit wekt de sugges-
tie dat de concentratiegrenzen gebaseerd zijn op wetenschappelijk zekere kennis en
op overeenstemming daarover. Dat is eigen aan kwantitatieve representaties. Het
onderzoek beschreven in dit proefschrift laat zien dat wetenschappelijke kennis over
effecten van stoffen op ecosystemen is omgeven met grote onzekerheden van uit-
eenlopende aard. Mijn proefschrift sluit daarmee aan bij onderzoek dat pleit voor
een explicitering van de onzekerheden waarmee wetenschappelijke kennis over
effecten van stoffen op mens en ecosystemen is omgeven. De huidige representatie
van stofnormen verdient een heroverweging. Een tweede belangrijke reden voor een
bw.souren 18-09-2006 15:47 Pagina 226
Het concept ‘grenswerk’ diende als uitgangspunt voor het interpretatief kader en
werd aangevuld met het concept ‘institutionele context’. Het onderscheiden van de
normatieve, regulatieve en cognitieve dimensie wekt de suggestie dat dat onder-
scheid in het empirisch materiaal zichtbaar of aanwijsbaar is. Dat is natuurlijk niet
zo! De onderzoeker maakt dat onderscheid en sorteert het empirisch materiaal uit.
Ook al worden dergelijk essentialistisch benaderingen graag bekritiseerd, opvallend
is hoe veel ze, ook door die onderzoekers, gebruikt worden. Een goede essentialisti-
sche benadering dwingt de onderzoeker om te beargumenteren waarom het empi-
risch materiaal zo kan worden uitgesorteerd en verrijkt daarmee het inzicht. Op
basis van mijn ervaringen met het concept van Scott kwalificeert het (nog) niet als
zodanig. De omschrijving van de dimensies is daarvoor nog onvoldoende uitge-
werkt. Daarmee blijven er voor de onderzoeker teveel vrijheidsgraden voor het uit-
sorteren van dat empirisch materiaal.
De twee concepten ‘grenswerk’ en’ institutionele context’ verschillen in meerde-
re opzichten. Die verschillen zijn terug te voeren op hun epistemologische uit-
gangspunt. Institutionele concepten richten het zoeklicht op stabilisering en dyna-
miek. Het werken met een institutioneel concept maakt grotere patronen en stabi-
lisering zichtbaar. Daarmee was het een geschikte benadering om de grotere lijnen
in de periode van 1971 tot 2000 te duiden. Voor het inzoomen op onderdelen van
die grotere lijnen is een institutioneel concept minder geschikt. Dan verdwijnt de
veronderstelde stabiliteit, en wordt de dynamiek zichtbaar. Het concept ‘grenswerk’
heeft een bijna tegenovergestelde uitwerking. Dat concept benadrukt activeit, dyna-
miek en verandering. Voor de contextuele analyse in dit proefschrift, waarbij cases
in hun context werden geplaatst werkte de combinatie van deze twee benaderingen
goed. In de analyse van de context werd gezocht naar stabiliteit, terwijl in de case
studies gezocht werd naar de dynamiek in de normstellingspraktijk. Zo kon het ver-
schil in epistemologische uitgangspunten juist benut worden om het inzicht te ver-
groten, en werden de beide concepten verenigbaar.
bw.souren 18-09-2006 15:47 Pagina 227
Dankwoord
227
Toen ik destijds het telefonisch sollicitatiegesprek voerde vanaf het hotel in Ghana
was ik overtuigd van mijn kansen en zag in dit promotieproject de mogelijkheid
mijn practische werkervaring op het grensvlak van wetenschap en beleid te kunnen
voorzien van een theoretische basis. Peter Groenewegen, Nico van Straalen en Eric-
Jan Tuininga gaven me het vertrouwen en de vrijheid om precies dat te doen. Dank
daarvoor! Zonder dat vertrouwen en die vrijheid had ik dit project niet tot dit einde
gebracht.
Geen van ons besefte hoe weerbarstig de praktijk van interdisciplinair onderzoek
zou blijken te zijn. We gingen, -gelukkig- voor de uitdagingen en kansen van deze
onderneming; de beren op de weg zouden zich te zijner tijd wel uit de voeten maken.
Peter Groenewegen, Nico van Straalen en Pieter Leroy, voor ingewijden ook wel
‘de mannen’. Jullie waren in die jaren over één ding zeer uitgesproken, oprecht en
eensgezind: het moest en kon beter! Over de contouren van het eindproduct en de
weg daarnaartoe waren jullie minder eensgezind en uitgesproken. Zo werd het soms
een behoedzaam manouvreren langs disciplinaire reflexen en het interdisciplinaire
vacuüm waarin niets meer duidelijk is. Het schip is nu binnen. Beste Peter, je was
mijn co-promotor en initiatiefnemer van het project. Ik heb een andere weg gelo-
pen dan jij had voorzien, maar we wisten er altijd weer uit te komen! Ik heb je niet
aflatende vertrouwen zeer gewaardeerd en heb veel respect voor de wijze waarop je
bent omgegaan met mijn keuze voor de detachering destijds naar Nijmegen.
Beste Nico, mijn eerste promotor. Tijdens ons eerste gesprek bekende je dat je
‘mijn onderzoek eigenlijk heel graag zelf zou willen doen’. Je was net zo junior als ik
als het ging om het vakgebied van de beleidswetenschappen en wetenschapsstudies.
Met mij kon je geboeid zijn door wat ik op mijn ondekkingstocht van die vakge-
bieden allemaal tegenkwam. Ook jij was niet gehinderd door al te veel voorkennis
bw.souren 18-09-2006 15:47 Pagina 228
me liet detacheren vanuit Amsterdam naar jouw leerstoelgroep werd je mijn twee-
de promotor. Ik had je uitgenodigd, en jij wilde graag. Je niet aflatende aandacht
voor de structuur en methodologie hebben het proefschrift beslist verbeterd. Meer
dan je je misschien realiseert heb jij daarmee bijgedragen aan mijn vorming tot
interdisciplinair wetenschapper.
Al degenen die ik voor het onderzoek beschreven in dit proefschrift heb geïn-
terviewd of gesproken dank ik voor hun bijdrage. Ze wijdden mij in in hun bele-
ving en namen daar steeds ruim de tijd voor. De leden van de manuscriptcommis-
sie: Herman Eijsackers, Jan Hendriks, Matthijs Hisschemöller, Jan Roels en Ad van
Dommelen dank ik voor de beoordeling van het manuscript en aanvullende com-
mentaren en suggesties.
Het opleidingsprogramma tijdens mijn AIO-aanstelling volgde ik bij de onder-
zoekscholen SENSE en WTMC. Workshops, zomerscholen en winterscholen
waren inspirerend en niet zelden confronterend. Roland Bal, Annemiek Nelis, Rob
Hagendijk, Willem Halffman, Tjalling Swierstra; jullie weten vast niet meer precies
wat je ooit hebt opgemerkt over mijn onderzoek, ik wel, waarvoor dank.
International conferences at EASST, EGOS, SETAC and EURAS were inspiring
and stimulating advice was provided especially by Sheila Jasanoff, Jane Summerton
and Elisabeth Shove. Discussions and comments during my visit to the Institute of
Public Policy (chaired by Hank Jenkins-Smith), University of New Mexico,
Albuquerque in 1999 turned out to be crucial for the set-up of my research. I am
grateful to have met with nice, knowledgeable and sincere members of the acade-
mic community and I enjoy being part of it.
Mijn collega’s van de Afdeling Algemene Vorming, Faculteit der Exacte Weten-
schappen, VU. Beste Eric-Jan, Annelie, Brigitte, Cees, Esther, Gerard, Ida, Inge,
Mies, Paulien, Peter G, Peter K, Rita en Tessa, we vormden samen de reflexieve luis
in de pels. Dat schiep een band. Tessa, kamergenoot op U222. We waren ‘de mei-
den’ maar wisten ons mannetje te staan. We deelden de passie voor Afrika, dus ik
snapte wel dat je naar Nairobi vertrok toen je de kans kreeg. Rita, we deelden meer
en het is bijzonder om ‘onze jongens’ groot te zien worden. Ida dank ik graag voor
het verlengen van mijn contract; dat was de juiste support op het juiste moment!
Beste collega’s van de Afdeling Dieroecologie, Faculteit der Aard- en Levensweten-
schappen, VU. We zagen elkaar niet met grote regelmaat, maar in de jaren in
Amsterdam heb ik me altijd betrokken gevoeld. De besprekingen van mijn werk in
bw.souren 18-09-2006 15:47 Pagina 229
het werkoverleg werden allengs aangenamer en hielden me sensitief voor het denk-
kader van de natuurwetenschappers. Esther, vooral in de beginfase van onze projec-
ten was het waardevol met jou ervaringen te delen. Naarmate we beiden vorderden
vonden we onze eigen weg.
Beste Marijke van Langen, Xander Kaspers, Ewout Krijger, Henri de Wolf en
Renate Heppener. Jullie droegen als studenten bij aan mijn onderzoek met de uit- 229
voering van jullie afstudeerproject, cursusopdracht en afstudeerscriptie. Marijke
Dankwoord
voerde haar afstudeerproject over de ontwikkeling van het Toegevoegd Risico-con-
cept uit bij de Technische Commissie Bodembescherming. Dat werk speelde een
beslissende rol bij de verdere uitwerking van het interpretatief kader voor het onder-
zoek beschreven in dit proefschrift. Jouw ijsvogel hangt ook weer op mijn nieuwe
werkkamer! Xander, Ewout en Henri onderzochten de besluitvorming rond zink-
normstelling. De resultaten van dat werk hebben bijgedragen aan de publicatie van
een artikel. Renate schreef een scriptie over de betekenis van het bodemonder-
zoeksprogramma NOBIS voor de ontwikkeling van het bodembeleid en droeg daar-
mee bij aan de derde casus beschreven in mijn proefschrift.
Vanaf Juni 2001 heb ik het onderzoek voortgezet aan de Radboud Universiteit,
Faculteit Managementwetenschappen, Leerstoelgroep Milieu en Beleid. Beste
Pieter, Bas, Bertien, Duncan, Elmar, Jaap, Jacques, Jan, Joris, Maria, Mariëlle, Mark
en Sietske, het was een genoegen om bij jullie de tweede helft van het onderzoek te
mogen doen. Als koekoeksjong in het nest mocht ik met verwondering en genoe-
gen het sociaal wetenschappelijk gedachtengoed verder verkennen.
Behalve de onderzoeksvraag was ik tijdens het onderzoek vaak bezig met de
vraag of die verbreding en mijn vorming tot interdisciplinair wetenschapper wel een
verbetering ging zijn. Of het perspectief zou bieden? Met mijn aanstelling als UD
Wetenschapscommunicatie aan de Faculteit Natuurwetenschappen, Wiskunde en
Informatica aan de Radboud Universiteit, Nijmegen kwam de erkenning dat dat
inderdaad zo was. Sinds April 2004 werk ik daar aan het Institute for Science,
Innovation and Society. De directe collega’s van de Afdeling Filosofie en Weten-
schapstudies vingen de stress op in de eindfase. Beste Hub, Ellen, Frans, Jozef, Leen,
Luca, Martijntje, Martin, Pieter, Riyan, Rob, Ron, Saskia, Wim, en alle CSG colle-
ga’s; dank voor de collegialiteit en de inspirerende omgeving. Het is er goed toeven.
Beste Hub, dank voor de tijd en de ruimte die je me gaf om het boek af te maken.
Beste Riyan, de vanzelfsprekendheid waarmee vooral jij mij uit de wind hield tij-
dens de afronding van het boek was onvergetelijk. Het jouwe komt er nu ook snel
aan. Ik ben verguld met jou als directe collega en paranimf!
Beste Bertien, Esther, Inge, Leen, Marleen, Penny, Simône; weer een proefschrift
af van de damesclub! Het was een genot om de AIO-blues met jullie te delen op
gezette tijden. Congresbezoek, tapas eten, praten over banen, jurkmannen en papers
was goed met jullie. Inmiddels hebben we in Zuid een nieuwe afdeling en zetten we
het forum voort met Annemiek, Els, Leen, Riyan, Simône, Ellen en Christien.
bw.souren 18-09-2006 15:47 Pagina 230
Beste Petra, mijn tweede paranimf. ‘Je hebt het nog niet helemaal door’ zo voeg-
de je me tijdens een van onze wandelingen onomwonden toe. En je had nog gelijk
ook. Dat er nog vele wandelingen mogen volgen. Beste Jacqueline, nu is mijn boek
ook af. Dank voor je vanzelfsprekende belangstelling en trouwe telefoontjes. Onze
vriendschap heeft al door heel wat fasen stand gehouden, ook in de afgelopen, iet-
230 wat magere jaren. Dat de vette jaren mogen volgen! Beste Zonnige Zussen, nu ga ik
nooit meer een Wandelweekend missen omdat ik moet doorwerken aan het proef-
Dankwoord
schrift. Heerlijk! Yvon, dank voor het mooie ontwerp van de kaft! Beste familie,
buren en vrienden in Oost en omstreken, het is een genot nu een kort antwoord te
kunnen geven. Het is af!
Lieve Pappa en Mamma, Ingrid, Remond en Annemarie en …, dank voor jullie
vertrouwen in al die jaren. Lieve Hans, in de periode die ik met dit proefschrift
afsluit hebben we onze levens verder uitgewerkt en verknoopt. We hebben verhalen
afgesloten en zijn nieuwe begonnen. Je zei het al eerder; het wordt alleen maar
mooier! Lieve Joris, dit is het geworden. Mamma’s boek is klaar.
Curriculum vitae
231
Astrid Souren werd geboren op 18 maart 1967 te Schimmert. Na het behalen van het
VWO-B diploma in 1986 aan het Stella Maris college te Meerssen, volgde zij de stu-
die Biologie aan de Universiteit Utrecht. Tijdens de studie waren ontwikkelingssa-
menwerking, onderwijsontwikkeling, plantenecologie en ecofysiologie de kernthe-
ma’s. Het doctoraalexamen werd behaald in augustus 1994. Aansluitend volgde in
1994 en 1995 een gastmedewerkerschap aan de Faculteit Biologie (UU) en werd een
haalbaarheidsstudie uitgevoerd naar de opzet van traineeships binnen de Faculteit
Biologie (de voorloper van wat later de Communicatieve en Maatschappelijke
Afstudeervariant werden in het bètaconvenant). In diezelfde periode heeft zij een
samenwerkingsverband tussen de Universiteit Utrecht, IUCN-Uganda, en Makarere
University in Uganda onderzocht over de duurzame exploitatie van bamboe uit
Mount Elgon NP, Uganda. Als consultant voor de Stichting AidEnvironment te
Amsterdam werden in 1995 en 1996 diverse projecten uitgevoerd voor de RMNO
(Raad voor Ruimtelijk, Milieu en Natuuronderzoek), waaronder het rapporteurschap
voor de commissie die het NWO Stimuleringsprogramma Systeemgericht
Ecotoxicologisch Onderzoek (SSEO) voorbereidde. In 1996 en 1997 volgde een aan-
stelling als trainee aan de Universiteit Utrecht, Faculteit Biologie, gedetacheerd aan het
(toenmalig) Staring Instituut (inmiddels onderdeel van Alterra) te Wageningen. Daar
heeft zij als projectleider het pilotproject ‘Assessing the role of natural vegetation in
inland valleys in West Africa’ uitgevoerd voor het Inland Valley Consortium in Ghana.
Van 1997-2003 volgde een aanstelling als AIO aan de Afdeling Algemene Vorming,
Faculteit Exacte Wetenschappen van de Vrije Universiteit Amsterdam en werd het
onderzoek uitgevoerd dat heeft geresulteerd in dit proefschrift. In 2001 werd de aan-
stelling tussentijds overgenomen door de Faculteit Biologie van de VU en volgde een
detachering naar de Leerstoelgroep Milieu en Beleid van de Faculteit
Managementwetenschappen, Radboud Universiteit Nijmegen.
bw.souren 18-09-2006 15:47 Pagina 232
Sinds April 2004 werkt Astrid Souren als Universitair Docent Wetenschaps-
communicatie aan het Institute for Science, Innovation and Society (ISIS) van de
Faculteit Natuurwetenschappen, Wiskunde en Informatica, Radboud Universiteit
Nijmegen. Onderzoek, onderwijs en curriculumontwikkeling zijn geconcentreerd
rond wetenschapscommunicatie, multi-, inter en trandisciplinariteit, kennissamen-
232 leving, en risico- en onzekerheidscommunicatie. Het onderwijs is onderdeel van de
Facultaire Afstudeervariant Wetenschapscommunicatie. Het onderzoek is ingebed
in de ISIS werkgroep Knowledge Society.